Summary of NAACP v. Patterson
Citation: 357 U.S. 449 (1958)
Relevant Facts: The National Association for the Advancement of Colored People (NAACP), one of the foremost civil rights organizations in the country, is organized under the laws of New York. In opening offices in Alabama, the organization failed to register with the State as required for foreign corporations. The State brought suit, attempting to enjoin the organization from further organizing efforts in that jurisdiction. During the course of that litigation, the trial court ordered the NAACP to turn over a variety or records, including membership lists. The Association eventually furnished most of the requested records but refused to surrender membership lists, resulting in a contempt citation and fine. Refused relief by the State Supreme Court, the NAACP challenged the contempt citation at the U.S. Supreme Court, claiming that required disclosure of membership lists significantly restrained their liberties and unconstitutionally infringed on their free association. While the suit named the State of Alabama, the NAACP also named Mr. Patterson (Attorney General of Alabama) in the case in his official capacity on behalf of the State.
Issue: Can a State, consistent with the requirements of the Fourteenth Amendment, compel an organization to disclose the names and addresses of all members without regard to their position within the organization?
Holding: No, a State cannot require general disclosure of membership rolls. Immunity from government scrutiny of membership lists is so central to the right to freely associate that it falls within the protections of the Fourteenth Amendment.
Reasoning : Justice Harlan, writing for the Court, first dismissed procedural issues. The Court determined that no state grounds existed for denial of relief, providing the Court with jurisdiction to entertain federal claims. Next, Justice Harlan explained that the NAACP had standing to assert rights on behalf of its membership. Turning to substantive issues, Justice Harlan explained the nature of free association, and dismissed the State’s argument that no direct limitations existed on members’ ability to associate freely. The right to privacy in one’s associations, the Court explained, is a key component of the liberty to associate at all. Furthermore, disclosure of membership information under the circumstances here would likely result in significant hardship to members and directly threaten their attempts to freely associate. Finally, the Court evaluated the legitimacy of the State’s interest in obtaining the requested disclosure. Alabama asserted a valid interest in verifying compliance with restrictions on intrastate commerce by foreign corporations, but the Court determined that membership lists were not necessary to that determination. Furthermore, the NAACP had already substantially complied with the disclosure request such that the trial Court could resolve the issues in that case. The Court distinguished the instant case from other matters in which the activities of the organization in question raised criminal concerns, namely previous cases involving harassment and intimidation at the hands of members of the Ku Klux Klan. In the absence of legitimate justifications for disclosure, and faced with the possibility of significantly curtailing fundamental rights, the Court held that required general disclosures exceed the authority of the State to regulate organizations by substantially hampering the liberty to associate.
Conclusion: Organizations cannot be required to disclose lists of rank-and-file members consistent with the free association rights guaranteed by the Fourteenth Amendment.