National Association for the Advancement of Colored People v. Alabama ex rel. Flowers (1963)
- Docket
- 169
- Decided
- 1963-01-01
Summary
Question: Was the NAACP properly barred from obtaining a hearing in Alabama courts because its brief did not conform to the rules of the Supreme Court of Alabama? Was this a state question barring federal review? Did Alabama properly enjoin the NAACP from acting in Alabama because the NAACP failed to comply with statutory requirements for foreign corporations? Did Alabama properly enjoin the NAACP from acting in Alabama because its political activities violated Alabama law? Conclusion: In a unanimous opinion written by Justice John Harlan, the Court held that the form of the NAACP’s brief should not prevent it from obtaining a hearing in Alabama courts. Justice Harlan first determined whether the form of the NAACP's brief was a state question barring federal review. He noted that the Court had already ruled that most of the formal requirements deprived the NAACP of its federal constitutional rights. Justice Harlan cited the Court’s prior reasoning on the NAACP’s claim, confirming that novelty in state procedural requirements cannot prevent parties from seeking to vindicate their federal constitutional rights in state courts. Justice Harlan also held that Alabama improperly applied the state registration requirements. He looked to the language of the statute, noting that the stated penalty for failure to comply was a forfeiture of one thousand dollars for each offense; there was no mention of permanent ouster in the statutory language. Justice Harlan determined that the purpose of the requirements was simply to ensure that foreign corporations would be amenable to suit in Alabama, and confirmed this interpretation through a brief overview of Alabama case law. Turning to Alabama’s other allegations, Justice Harlan held that the vast majority of the NAACP’s actions did not violate any particular Alabama law, and all of its actions were constitutionally protected or controllable by other, more appropriate public remedies. Justice Harlan rejected Alabama’s contentions that the NAACP illegally 1) paid for two black students to attend the University of Alabama, 2) failed to disclose membership information, 3) made false allegations against state officials, 4) violated Alabama’s injunction, and 5) breached the peace, along with several other allegations. He argued that these activities were more related to the NAACP’s members’ freedom to associate for the collective advocacy of their ideas than to the NAACP’s privilege to do business in Alabama.