National Assn. for Advancement of Colored People v. Alabama

In National Assn. for Advancement of Colored People v. Alabama (357 U.S. 449 [1958] [hereinafter NAACP]) the Court reviewed a judgment holding the NAACP in contempt for refusing to disclose to the Attorney General a list of its rank-and-file members. The Attorney General demanded the list pursuant to a statute that required a foreign corporation to qualify before doing business in the State. According to the State of Alabama, the list was necessary to determine whether the NAACP was conducting intrastate business in Alabama in violation of the statute. The NAACP resisted disclosure on the ground that "the effect of compelled disclosure of the membership lists will be to abridge the rights of its rank-and-file members to engage in lawful association in support of their common beliefs." (NAACP, supra, at 460.) On the record before the Court was an "uncontroverted showing that on past occasions revelation of the identity of its rank-and-file members has exposed these members to economic reprisal, loss of employment, threat of physical coercion, and other manifestations of public hostility." (Id., at 462.)