National Association for the Advancement of Colored People v. Alabama
By ensuring the privacy of members of associations pursuing legal ends, the Court protected supporters of the Civil Rights Movement who might have faced persecution had their names been known, and thereby aided the movement in attracting new members. The refusal to consider the association's challenge to the state restraining order effectively prevented the NAACP from operating in Alabama until 1964.
The 1950s were a period of great social change in the southern United States. In the aftermath of World War II, during which many African Americans rose to positions of responsibility in the military and industry, new challenges emerged to those southern social structures which included racial segregation. Organizations representing the interests of African Americans, such as the National Association for the Advancement of Colored People (NAACP), began wielding increased influence and receiving some assistance from federal authorities in areas including school desegregation. This newfound power brought a reaction from state and local authorities and from citizen groups willing to use threats and physical intimidation to protect the social status quo.
In December of 1955, Rosa Parks, an African American, refused to relinquish her seat to a white person on a Montgomery, Alabama bus in violation of city law. Parks was subsequently arrested and convicted, touching off a boycott by African Americans of the Montgomery public transportation system. As the boycott continued, tensions heightened and, in June 1956, Alabama attorney general John Patterson took action to curtail the NAACP's influence in the state, enjoining the NAACP to produce lists of its members and contributors. His actions were based on the grounds that the NAACP had failed to adhere to state requirements that organizations which were headquartered out-of-state had to file charters with the secretary of state, designate a place of business in the state, and name an agent to receive service of process. The NAACP quickly complied with these requirements, but refused to provide the membership and contributor lists. The Alabama State Circuit Court cited the NAACP for contempt for failure to provide the lists, and also issued an order restraining the association from operating in Alabama until it produced the lists required. Two appeals to the Alabama Supreme Court to review the contempt judgement by the NAACP were rejected, but the U.S. Supreme Court agreed on certioroari to hear the case.
Lawyers for the state of Alabama argued that the Supreme Court did not have jurisdiction in this case since the Alabama Supreme Court had denied certiorari on the (nonfederal) grounds that the NAACP was pursuing an incorrect appellate remedy under state law. NAACP attorneys countered that Alabama's order for the association to produce a list of its members and benefactors violated the Due Process Clause of the Fourteenth Amendment, guaranteeing individuals the right to form associations in support of their common and lawful beliefs. They further asserted that Alabama's temporary restraining order barring the NAACP from operations in the state was unconstitutional on Fourteenth Amendment Grounds.
Justice Harlan delivered the opinion of the Court. Alabama's contention that the Court lacked jurisdiction in the case was rejected, the Court believing that certiorari rather than appeal was the most proper way to review action in the case to date. The Court also held that the NAACP was not obliged to disclose its membership and donor lists, stating that:
. . . advocacy of both public and private points of view, particularly controversial ones, is undeniably enhanced by group association . . . [it is] beyond debate that freedom to engage in association for the advancement of beliefs and ideas is an inseparable aspect of the "liberty" assured by the Due Process Clause of the Fourteenth Amendment, which embraces freedom of speech . . . [Furthermore], inviolability of privacy in group association may be in many circumstances indispensable to preservation of freedom of association, particularly where a group espouses dissident beliefs.Finally, the Court ruled against the NAACP in the matter of the state of Alabama's restraining order against the association. The Court essentially agreed with the state of Alabama's argument regarding the disclosure of membership and donor lists, holding that since the NAACP had never received a hearing in a state court regarding the merits of the restraining order the Supreme Court did not have jurisdiction over the matter.
Although the Court's refusal to remove the state restraining order greatly restricted NAACP activities in Alabama for more than a decade, its decision not to compel the association to disclose its membership and donor lists proved of great benefit to the Civil Rights Movement and to other causes of a socially or politically controversial nature. The ability of dissident groups to keep their membership a secret makes their individual members far less easy to target for intimidation or discrimination, which in turn allows such groups far greater scope for broad-based recruitment.
- National Association for the Advancement of Colored People v. Alabama - Related Cases
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