Thursday, November 14, 2013

NAACP v. State of Alabama Ex. Rel. Patterson case brief

NAACP v. State of Alabama Ex. Rel. Patterson case brief summary
357 U.S. 449 (1958)

Respondent State of Alabama had brought an equity suit against petitioner association that resulted in a discovery order. The association failed to comply with the discovery order, which compelled the production of the association's membership lists. The association challenged a decision of the Supreme Court of Alabama that twice dismissed petitions for certiorari to review a final contempt judgment.

A civil contempt order was entered against the association when it refused to present to the State a list of the names and addresses of all its Alabama members and agents. The association claimed that the order violated rights assured to the association and its members under the Federal Constitution. The association filed two petitions with the state supreme court requesting certiorari on the issue of the civil contempt order. The court twice dismissed the petitions, the first one for insufficiency of the petition's allegations and the second time on procedural grounds. The association requested certiorari to the court, which was granted.


  • The court reversed the lower court's decision and remanded the cause. 
  • The court held that the immunity from state scrutiny of membership lists, which the association claimed on behalf of its members, was so related to the right of the members to associate freely with others so as to come within the protection of U.S. Constitutional Amendment XIV. 
  • The State failed to show a controlling justification for the deterrent effect on the freedom to associate, which disclosure of the membership lists was likely to have.
The court reversed and remanded the lower court's decision.

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