NAACP v. Claiborne Hardware Co.
Citation and Court
458 U.S. 886 (1982), Supreme Court of the United States
Facts
In 1966, the NAACP organized a boycott of white-owned businesses in Port Gibson, Mississippi to pressure local governments to comply with civil rights demands. The boycott involved speeches, marches, and picketing. White merchants sued under state antitrust and tort law, winning a judgment of over $1 million. The Mississippi Supreme Court affirmed on both antitrust and tort grounds.
Issue
Whether a noncommercial political boycott organized by a civil rights group is subject to state antitrust law or is protected by the First Amendment.
Holding
The First Amendment protects noncommercial political boycotts aimed at achieving political ends; the Sherman Act and state antitrust laws do not apply to such activity because it is not commercial in nature.
Rule / Doctrine
The Sherman Act reaches only commercial activity and does not cover politically motivated, noncommercial boycotts. Moreover, the First Amendment protects the right to associate for political purposes and to advocate for political change through collective action, including organized boycotts, as long as there is no incitement to imminent lawless action.
Significance
Claiborne Hardware draws the boundary between antitrust-regulated commercial activity and First Amendment-protected political association. It is the definitive statement that politically motivated, noncommercial boycotts fall outside the Sherman Act and are constitutionally protected speech and assembly.