Cameron v. Johnson

1968-06-03

Headline: Court upholds Mississippi anti-picketing law and refuses to block prosecutions, allowing state officials to enforce obstruction-based limits on courthouse picketing that affected civil-rights protesters.

Holding: The Court affirmed the lower court, holding the Mississippi statute is not facially void and denying an injunction because the record shows no bad-faith enforcement, so state prosecutions for obstructive courthouse picketing may proceed.

Real World Impact:

Allows states to enforce anti-picketing laws when picketing obstructs courthouse access.
Permits prosecutions to proceed unless plaintiffs show officials enforced law in bad faith.
Limits federal courts from blocking prosecutions absent clear harassment evidence.

Topics: picketing restrictions, voting-rights protests, free speech and assembly, state law enforcement

Summary

Background

A group of civil-rights organizations and their members picketed the Forrest County voter registration office at the Hattiesburg courthouse from January 22 to May 18, 1964, to protest racial discrimination and encourage Black citizens to register. Mississippi enacted an Anti-Picketing Law on April 8, 1964, forbidding picketing that "obstructs or unreasonably interferes" with ingress or egress to public buildings. After arrests on April 10, 11, and May 18 for violating the new law, the protesters sued in federal court seeking a declaration that the law was facially void and an injunction to stop state prosecutions as bad-faith harassment.

Reasoning

The Court addressed whether the statute was vague or overly broad and whether federal equity should block the prosecutions. Relying on the statute’s language, the Court held it targets obstructive conduct, not speech, and is not facially invalid. The Court also held that an injunction is improper absent "special circumstances" of bad-faith enforcement; the record showed the arrests were prosecuted in good faith, so the district court properly denied injunctive relief and the prosecutions may proceed.

Real world impact

This decision lets Mississippi and similar states enforce obstruction-based limits on picketing at public buildings so long as officials act in good faith. Protesters accused under such statutes must defend themselves in criminal trial and on appeal; federal courts will intervene only where there is clear evidence the law is being used to harass protected expression.

Dissents or concurrances

Justice Fortas, joined by Justice Douglas, dissented, arguing the record shows peaceful, tolerated picketing and that the law and its immediate enforcement were deployed in bad faith to stop civil-rights demonstrations, requiring federal relief under Dombrowski.