NAACP v. Alabama

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NAACP v. Alabama
Court Supreme Court of the United States
Citation
Date decided June 30, 1958
Appealed from Alabama Supreme Court

Procedural History

John Patterson, the Attorney General of Alabama, sues the NAACP in 1956. The trial court issued an order to NAACP for not meeting the state's requirement to conduct business in Alabama.

Alabama moved to compel NAACP to disclose its records including its members names.

Issues

Would compelling an organization to reveal its membership list violate the freedom of association of the members of the organization under the First Amendment?

Arguments

NAACP argued that disclosing the names and addresses of its members would have a chilling effect on the association rights of its members.

Holding

The due process clause of the 14th Amendment protects the right to freely associate with other people.

The state of Alabama must demonstrate a compelling state interest to demand the disclosure of the membership list of NAACP (strict scrutiny).

Comments

The phrase "freedom of association" isn't found anywhere in the US Constitution. Therein, the phrase "peaceably to assemble" is used.

Nonetheless, US courts have recognized the right of people to associate with other people. US courts treat association akin to assembly together for a common cause.

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