In 1958, the United States Supreme Court heard the case of the National Association for the Advancement of Colored People v. Alabama. Although a little known case, the decision was not only important to the NAACP, but for all organizations who promote beliefs and ideas, along with the individual people who associated with them.
The reason for the creation of this case was a state law in Alabama concerning foreign groups operating within the state. Many officials in the government of the state of Alabama did not want to have the NAACP, a civil rights organization, operating in their state.
In order to prevent them from doing this, a subpoena was issued to the organization for records and membership lists relating to the state of Alabama. The purpose, the state claimed, was to determine if the NAACP was a qualified foreign corporation allowed to operate in Alabama under state law.
The subpoena was issued in 1956 by the Attorney General for the state of Alabama. The NAACP, although headquartered in New York, was a non-profit corporation and thought themselves exempt from being a foreign corporation in Alabama.
If the civil rights organization did not comply, the state wanted the NAACP to stop doing business and leave. But the organization did not comply with the request for their list of members; they were found to be in contempt of court and consequently fined.
The United States Supreme Court reversed the contempt ruling on two occasions before the issue went to trial in the Alabama State Circuit Court. The circuit court ruled against the association and later the State Appellate Court denied them their appeal.
The United States Supreme Court then heard the case on January 15th and 16th. The question before the court was to determine if the demands by the state of Alabama, were a violation of the due process guaranteed by the Fourteenth Amendment of the Constitution.
In particular, it was the demand of the membership lists themselves, and not the financial records to enforce an Alabama state law on foreign corporations operating in the state.
On June 30th 1958, the issue was decided by a unanimous vote of nine to zero.
The court ruled that obtaining the names on membership lists violated private interests to freely associate others, which is a protected right under the Fourteenth Amendment. In addition, the Alabama law violated an individual’s right to belong to organizations which advanced beliefs shared by an individual.