Gibson v. Florida Legislative Investigation Committee

Summary

The Court reversed the contempt judgment against the president of the Miami branch of the NAACP, holding that the Florida legislative committee had not established a substantial connection between the organization and Communist activity sufficient to justify compelled use of its membership records. Although legislative investigations may address legitimate and vital interests, particular demands that substantially intrude on associational rights require a demonstrated compelling governmental interest and adequate factual foundation. Justices Harlan and White dissented, arguing that the committee had sufficient evidence and that the limited use of the records did not meaningfully interfere with association; Justices Douglas and Black concurred on broader grounds protecting association from governmental inquiry.