GIBSON v. FLORIDA LEGIS. INVESTIGATION COMM.

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Case Basics
Docket No. 
6
Petitioner 
Gibson
Respondent 
Florida Legis. Investigation Comm.
Reargued: 
Tags
Term:
Facts of the Case 

In the wake of the Supreme Court's ruling in Brown v. Board of Education, the National Association for the Advancement of Colored People (NAACP) received much criticism from state legislators as it pushed ahead with litigation to combat segregation. The State of Florida, in 1959, established a Legislative Investigation Committee to study what were called "subversive organizations." Gibson, president of the Miami branch of the NAACP, was subpoenaed before the committee and asked to produce a membership list of his organization. He refused and was found in contempt.

Question 

Did the Florida Committee, in attempting to inform itself about activities of subversive organizations, violate Gibson's right to free speech and association as protected by the First and Fourteenth Amendments?

Conclusion 

In a close decision, the Court found that Gibson's rights had been violated. In his opinion, Justice Goldberg recognized the important right of states to inform themselves on "legitimate and vital interests." However, even though inquiring about the actions of a group such as the Communist Party may have been one of these legitimate interests, argued Goldberg, Florida did not prove that a "substantial connection" between the Miami NAACP and Communist Party activities existed. Thus, a "compelling and subordinating governmental interest" would not have been served by forcing Gibson to disclose his group's membership list.

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GIBSON v. FLORIDA LEGIS. INVESTIGATION COMM.. The Oyez Project at IIT Chicago-Kent College of Law. 31 August 2014. <http://www.oyez.org/cases/1960-1969/1961/1961_6>.
GIBSON v. FLORIDA LEGIS. INVESTIGATION COMM., The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/1960-1969/1961/1961_6 (last visited August 31, 2014).
"GIBSON v. FLORIDA LEGIS. INVESTIGATION COMM.," The Oyez Project at IIT Chicago-Kent College of Law, accessed August 31, 2014, http://www.oyez.org/cases/1960-1969/1961/1961_6.