National Association for the Advancement of Colored People v. Button

When Brown v. Board of Education ordered an end to school segregation in 1954, Virginia reacted violently. In spring of 1956, Senator Byrd coined the phrase "massive resistance" to characterize Virginia's response. The state adopted a resolution to "take all appropriate measures honorably, legally and constitutionally available . . . [in order] to resist [the Court's] illegal encroachment upon [Virginia's] sovereign powers." (S.J.Res. 3, 1956 Va. Acts 1213.)

Meanwhile, the NAACP's Legal Defense Fund was concentrating its efforts on claiming the Brown victory. Their chief strategy was litigation: staff attorneys represented those who were denied desegregated schooling. Ordinarily, the NAACP funded only suits in which NAACP attorneys were retained, though there were exceptions to this. Although the NAACP did not direct the attorney's actions in a suit, staff attorneys were expected to follow NAACP policies. States in the South--Virginia and others--responded with legislation designed to hinder or evict the organization. A string of Supreme Court cases answered these efforts.