On June 30, 1958—54 years ago today—the Supreme Court in NAACP v. Alabama took a stand in favor of individuals’ constitutional rights, asserting that Alabama’s demand for the NAACP’s membership lists violated the due process clause of the Fourteenth Amendment.
In 1956, Alabama Attorney General John Patterson sued the NAACP, claiming that the civil rights organization violated a state law which required out-of-state companies to file their corporate charter with state officials and designate an agent to act on the company’s behalf.
After the NAACP refused to capitulate to a state judge’s orders to cease operations and produce records—including the names and addresses of its members—the organization was fined $10,000. While the NAACP was willing to turn over some records, it was unwilling to produce the membership lists.
After the Alabama Supreme Court twice refused to review the case, the United States Supreme Court agreed to hear arguments.
In a unanimous decision, the Court ruled that Alabama’s demand violated the due process clause of the Fourteenth Amendment. The disclosure of membership lists, the Court argued, would suppress legal association among the group’s members—in fact, earlier disclosures of member identities had led to loss of employment, physical coercion, and other hostile treatment.
The ruling read, in part:
Effective advocacy of both public and private points of view particularly controversial ones, is undeniably enhanced by group association, as this Court has more than once recognized by remarking upon the close nexus between the freedoms of speech and assembly. . . 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. . .
. . . This court has recognized the vital relationship between freedom to associate and privacy in one’s associations. . . Inviolability of privacy in group associations may in many circumstances be indispensable to preservation of freedom of association, particularly where a group espouses dissident beliefs.
The Court did not rule on the legality of the NAACP’s work in Alabama, but it did overturn the contempt order and the fine. The decision signaled an important acknowledgement of the freedom of association, and paved the way for future success in the struggle against racial discrimination.
To read the full text of the decision, click here.
To listen to the oral argument, click here.
To read a news article printed at the time, click here.
To learn more about the NAACP, click here.
To learn about the controversial John Patterson, who became Governor one year after NAACP v. Alabama, check out Gene Howard’s Patterson for Alabama: The Life and Career of John Patterson (University of Alabama Press, 2008).
To learn about African Americans’ struggle for civil rights during the next decade in Alabama, check out Frye Gaillard’s Cradle of Freedom: Alabama and the Movement that Changed America (University of Alabama Press, 2004) and Alabama’s Civil Rights Trail (University of Alabama Press, 2010).