NAACP v. Claiborne Hardware Co

Brief Fact Summary.

Beginning in 1966, under the direction of the Petitioner, the Mississippi National Association for the Advancement of Colored People (NAACP) (Petitioner), black citizens began to boycott the businesses of several white merchants, on the basis of racial injustice. The Respondents, Claiborne Hardware Co. and other merchants (Respondents), brought suit asking for damages, alleging that their businesses had suffered due to the boycott.

Synopsis of Rule of Law.

The freedom to associate includes the freedom to demonstration, provided that a demonstration does not lead to violence.

Facts.

Beginning in 1966, under the direction of the Petitioner, black citizens began to boycott the businesses of several white merchants, on the basis of racial injustice. The Respondents brought suit asking for damages, alleging that their businesses had suffered due to the boycott. In 1976, ten years after the beginning of the boycott, the Trial Court held for the Respondents and awarded damages for lost business, in excess of $1.25 million. The Supreme Court of the State of Mississippi upheld the imposition of liability under the theory of malicious interference, and the Petitioner appealed to the United States Supreme Court (Supreme Court).

Issue.

This case considers whether demonstrators in a boycott, who are exercising their right to freely associate, can be held liable for damages caused to a business as a result of the boycott.

Held.

Reversed.
The Court held that, while a boycott may have the affect of disrupting business, a merchant cannot sue for damages when the demonstration is nonviolent and voluntary. Where, however, violence is used, the individual inciting the violence may be held liable for the damages caused by his actions.
Concurrence. Judge William Rehnquist (J. Rehnquist) concurred

Discussion.

Included in the right to freely associate is the right to demonstrate and align one’s self with the ideals of the association.