NAACP v. Alabama

Following is the case brief for NAACP v. Alabama, 357 U.S. 449 (1958)

Case Summary of NAACP v. Alabama:

  • The State of Alabama had a business statute that required foreign corporations to qualify with State officials before doing business in the State.
  • The National Association for the Advancement of Colored People (NAACP) is a non-profit corporation created in New York.  It set up an office in Alabama and believed it was exempt from the qualification statute.
  • The State, however, sued stating that the NAACP did not qualify with State officials and that its activities caused injury to the State.  It sought an order barring the NAACP from any further activities in the State.
  • An Alabama court restrained the NAACP, and it ultimately held the NAACP in contempt for not producing a membership list.
  • Once the case reached the U.S. Supreme Court, the Court determined that the NAACP cannot be required to provide a membership list under the Due Process Clause of the Fourteenth Amendment.  The Court held that the demand for a membership list would deter people from enjoying their right to freedom of association.

NAACP v. Alabama Case Brief

Statement of the Facts:

The State of Alabama had a statute requiring any foreign corporation to qualify in the State before doing business.  To qualify, the corporation must file its corporate charter with the Secretary of State and designate a place of business and contact agent.  Doing business before qualifying resulted in criminal prosecution for the corporation’s officers.

The NAACP, a non-profit corporation created under the laws of New York, set up a location in Alabama.  The NAACP did not comply with the qualification statute because it believed it was exempt.

Procedural History:

  • The State Attorney General sued in State court to enjoin the NAACP from conducting any activities in the State, alleging that it caused irreparable injury to the State.
  • The court immediately restrained the NAACP from any activities and forbade it from trying to qualify itself in the State.
  • The NAACP moved to dissolve the restraining order and alleged that the State’s attempt to silence the NAACP was unconstitutional.
  • The State then moved for production of documents from the NAACP, including membership lists. The court ordered the production.
  • The NAACP tried to qualify itself under the statute, but refused to comply with the court’s order to produce documents.
  • The court then held the NAACP in contempt and fined it $10,000, to be increased to $100,000 if the NAACP continued to refuse to produce the required documents.
  • The NAACP produced most of what was requested, except its membership lists.
  • The court responded by increasing the fine to $100,000 and continuing the contempt order, which foreclosed the NAACP from getting a hearing on the merits of the case or dissolving the temporary restraining order.
  • The Alabama Supreme Court twice refused to hear arguments on lifting the contempt order.
  • The U.S. Supreme Court granted certiorari.

Issue and Holding:

Can a State compel the NAACP to reveal the names and addresses of all its members consistent with the Due Process Clause of the Fourteenth Amendment?  No.

Judgment:

The decision of the Alabama Supreme Court is reversed and remanded.

Rule of Law or Legal Principle Applied:

A private group wishing to pursue private goals and associate freely is protected by the Fourteenth Amendment’s Due Process Clause such that a State’s attempt to obtain the group’s membership list must be denied.

Reasoning:

With regard to the initial matter of jurisdiction, the Alabama Supreme Court’s denial was not based on adequate state law, and the U.S. Supreme Court has the jurisdiction to hear the NAACP’s federal claims.  Further, the State is wrong to assert that the NAACP lacks standing.  Even though the individual members are not parties to the litigation, the NAACP itself can assert constitutional claims on behalf of its members.

Freedom to associate is protected by the Due Process Clause of the Fourteenth Amendment.  Effective advocacy is undeniably enhanced by group association.  Privacy in group association may be indispensable to preserving the right to freedom of association, especially on controversial issues.

The State’s order to produce a membership list will put a substantial restraint on the members’ freedom to associate.  It will dissuade people from joining, or continuing as members, for fear of reprisals.  Past history has shown that exposing the identity of members of dissident groups has resulted in economic and physical injury to those identified.

Moreover, Alabama has not demonstrated a State interest sufficient to justify its infringement on the NAACP members’ freedom to associate.

Significance:

NAACP v. Alabama is a landmark case that is seen as a huge victory for privacy and the freedom to privately associate.  Because of this case, a government cannot force a group to identify its members unless there is a compelling state interest in disclosure.

Student Resources:

Read the Full Court Opinion

Listen to the Oral Arguments

 

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