Supreme Court of the United States
Gibson v. Florida Legislative Investigation Committee
March 25, 1963372 U.S. 539
Summary
The Supreme Court reversed the Florida Supreme Court’s contempt judgment, holding that the state legislative committee could not compel the NAACP’s Miami branch to disclose its membership lists because the committee failed to show a substantial nexus between the organization and alleged subversive activity, and thus violated First and Fourteenth Amendment associational rights.
Holding
- Whether a state legislative investigative committee may compel disclosure of a lawful organization’s membership lists absent a substantial relation to subversive activity. The committee may not compel disclosure because it failed to demonstrate a substantial relation (nexus) between the NAACP Miami branch and any compelling state interest, and such disclosure infringes protected associational rights.
- Whether the Florida committee demonstrated a sufficient nexus between the NAACP Miami branch and Communist infiltration to justify the subpoena. The committee’s evidence—hearsay about fourteen alleged Communists who may have attended public meetings—was insufficient to establish a substantial nexus, so the subpoena was invalid.
Docket 6