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NAACP v. Alabama

    Citation. 377 U.S. 288, 84 S. Ct. 1302, 12 L. Ed. 2d 325 (1964)

    Brief Fact Summary. The Supreme Court of the United States (Supreme Court) held unconstitutional Alabama’s demand that the NAACP reveal the names and addresses of all of its Alabama members and agents.

    Synopsis of Rule of Law. In the domain of indispensable liberties, whether of speech, press, or association, abridgments of such rights, even though unintended, may inevitably follow from varied forms of governmental action. Compelled disclosure of affiliation with groups engaged in advocacy may constitute an effective restraint on freedom of association.


    Facts. The Respondent, Alabama (Respondent), demanded that the Petitioner, the NAACP (Petitioner), provide a list of all of the Alabama NAACP members based on the state’s foreign corporation registration law made in the course of an injunction action brought to stop the Petitioner from conducting activities in the state. Respondent moved for the production of a large number of the Petitioner’s records. The Petitioner produced almost all the requested data except for membership lists. The trial court adjudged the Petitioner in contempt and imposed a $100,000.00 fine.

    Issue. Whether compelled disclosure of membership lists violates the Petitioner’s members’ rights of freedom of association?
    Whether Respondent has demonstrated an interest in obtaining the membership lists, which is sufficient to justify the deterrent effect which releasing this lists would have on the free exercise of the constitutionally protected right of association?

    Held. Yes. Judgment of the lower court reversed. In the domain of indispensable liberties, whether of speech, press, or association, abridgments of such rights, even though unintended, may inevitably follow from varied forms of governmental action. Compelled disclosure of affiliation with groups engaged in advocacy may constitute an effective restraint on freedom of association. There is a vital relationship between freedom to associate and privacy in one’s associations. This production order must be regarded as entailing the likelihood of a substantial restraint upon the exercise by the Petitioner’s members of their freedom of association. Further, it is apparent that forced disclosure would result in adversely affecting the members to pursue their collective effort to foster beliefs, which they have the right to advocate. Therefore, compelled disclosure of membership lists violates the Petitioner’s members’ rights of freedom of association.
    No. Judgment of the lower court reversed. The Petitioner has not objected to divulging the identity of its members who are employed or hold office positions. There is no justification for the interest of obtaining membership lists.

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    Discussion. This case holds that disclosure of the membership lists is unconstitutional partly based on the “chilling effect” that it would have on the freedom of association.

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