NAACP vs. Alabama: A Brief
NAACP v. Alabama (1958)
I. Facts: In an effort to oust the NAACP from operating in the state, Alabama accused the NAACP of failing to comply with a state statute that required foreign corporations to register with the state before operating, which had been violated when the organization began operating in Alabama in 1914. After the organization tendered the necessary documentation, Alabama refused to accept it and instead ordered the release of the names and addresses of all member and agents of the organization living in the state. After only releasing the names of directors and officers in the state, the NAACP was found in contempt and fined $100,000. The NAACP appealed the decision of the state courts (which sided with the state government) to the Supreme Court, arguing that the Fourteenth Amendment protected the freedom of speech and assembly from discrimination.
II. Issue: Does the compelled disclosure of membership rosters violate the Petitioner’s (and those they represent) right to freedom of association under the Due Process Clause of the Fourteenth Amendment?
III. Holding: Yes. Alabama requiring the NAACP to release the information of their general members violates the Due Process clause of the Fourteenth Amendment.
IV. Reasoning: The court decided in favor of the NAACP because "immunity from state scrutiny of petitioner's membership lists is here so related to the right of petitioner's members to pursue their lawful private interests privately and to associate freely with others in doing so as to come within the protection of the Fourteenth Amendment". The court also held that the freedom to associate with groups attempting to advance beliefs or ideas is an integral part of the Due Process Clause of the Fourteenth Amendment. No matter how controversial or unpopular the group, when American citizens voluntarily join a peaceful organization, they are entitled to center level of privacy.
V. Decision: Supreme Court affirmed the right of the
I. Facts: In an effort to oust the NAACP from operating in the state, Alabama accused the NAACP of failing to comply with a state statute that required foreign corporations to register with the state before operating, which had been violated when the organization began operating in Alabama in 1914. After the organization tendered the necessary documentation, Alabama refused to accept it and instead ordered the release of the names and addresses of all member and agents of the organization living in the state. After only releasing the names of directors and officers in the state, the NAACP was found in contempt and fined $100,000. The NAACP appealed the decision of the state courts (which sided with the state government) to the Supreme Court, arguing that the Fourteenth Amendment protected the freedom of speech and assembly from discrimination.
II. Issue: Does the compelled disclosure of membership rosters violate the Petitioner’s (and those they represent) right to freedom of association under the Due Process Clause of the Fourteenth Amendment?
III. Holding: Yes. Alabama requiring the NAACP to release the information of their general members violates the Due Process clause of the Fourteenth Amendment.
IV. Reasoning: The court decided in favor of the NAACP because "immunity from state scrutiny of petitioner's membership lists is here so related to the right of petitioner's members to pursue their lawful private interests privately and to associate freely with others in doing so as to come within the protection of the Fourteenth Amendment". The court also held that the freedom to associate with groups attempting to advance beliefs or ideas is an integral part of the Due Process Clause of the Fourteenth Amendment. No matter how controversial or unpopular the group, when American citizens voluntarily join a peaceful organization, they are entitled to center level of privacy.
V. Decision: Supreme Court affirmed the right of the