NAACP v. Alabama

Brief Fact Summary. The Respondent, the Attorney General of the State of Alabama (Respondent) brought suit against the Petitioner, the National Association for the Advancement of Colored People (NAACP) (Petitioner), seeking to enjoin it from conducting further activities in the state, alleging that it had caused political upheaval in the state. The Respondent sought to discover a list of the members of the Petitioner association, which it refused to provide.

Synopsis of Rule of Law. This case is the first among several dealing with the First Amendment freedom of association. Membership in an association is not always a matter of public record and as it is a means of speech (in aligning with the viewpoints of the association), said membership should be protected.

Facts. The facts of this case come out of the 1950’s institutions of segregation. The Petitioner recruited members and set up offices in the state of Alabama. Due to its influence, African American students sought admission to universities and boycotts took place throughout the state. In an attempt to quell the upheaval, the Respondent sought to enjoin the activities of the organization. When the Petitioner refused to provide a list of its members, it was fined for contempt of court. The Petitioner appealed.

Issue. The case turns on the question of whether the Respondent’s interest in obtaining association membership is sufficient to justify the deterrent affect that could arise from disclosure of that information.

Held. Reversed.
Justice John Harlan (J. Harlan), in writing for the majority, found that compelled disclosure of membership is likely to have an adverse affect on an individual and would impact the right of free association, which is protected by the First Amendment of the United States Constitution (Constitution).

Discussion. The right to association is to be afforded First Amendment protection. An association cannot be compelled to give information regarding its members when no justification exists that outweighs the potential harm and abridgment to the individual member’s rights.