Bates v. City of Little Rock: The Background
The case of Bates v. City of Little Rock was a Supreme Court Case that held the First Amendment to the United States Constitution outlawed state governments to compel the disclosure of an entity’s membership lists via a tax-regulatory scheme.
The issue surrounding Bates v. City of Little Rock was whether the city of Little Rock, Arkansas’s license tax ordinance, which required the compulsory disclosure of a local organization’s membership list to verify its tax-exempt status, unconstitutionally places a burden on the freedom of association of an organization’s member. The case of Bates v. City of Little Rock was one of several First Amendment and civil rights cases argued in the United States Supreme Court by NAACP members.
Bates v. City of Little Rock: The Particulars
The case of Bates v. City of Little Rock began when custodians and petitioners of the local branches of the National Association for the Advancement of Color People were tried convicted and fined for violating the Little Rock identical occupational license tax ordinance. These people were punished because they refused to furnish city officials with documents or lists of the names of the members of Association’s local branches. The case was tried and the individuals of the NAACP were originally convicted. When appealed; however, the courts reversed the decision by claiming that compulsory disclosure of membership lists violates the groups’ freedom of association, which is wholly protected by the Due Process Clause of the Fourteenth Amendment.
Bates v. City of Little Rock: The Decision
The Supreme Court in Bates v. City of Little Rock ruled that state governments were not allowed to compel the disclosure of an organization’s membership lists when it directly impedes or affects the member’s freedom of association.
The case of Bates v. City of Little Rock has long been viewed as a companion case to the NAACP v. Alabama, which also ruled that NAACP membership records are wholly protected under the First Amendment to the United States Constitution, particularly the freedom of association clause. Also, the case of Bates v. City of Little Rock is closely related to Talley v. California which held that Talley, a popular civil rights leader, could not be fined for distributing anonymous flyers.
These cases, particularly the case of Bates v. City of Little Rock, helped establish and further define the right to privacy clause under the First Amendment to the United States Constitution.