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.