Healy v. James

408 U.S. 169 (1972)

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Nature of the Case

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Facts

Ps formed a local chapter of the SDS (Students for a Democratic Society) at D. There had been widespread civil disobedience on some campuses, accompanied by the seizure of buildings, vandalism, and arson. Ps attended D, a state-supported institution of higher learning. They organized a 'local chapter' of SDS. Ps filed a request for official recognition as a campus organization with the Student Affairs Committee, a committee composed of four students, three faculty members, and the Dean of Student Affairs. Ps were alleging they would provide 'a forum of discussion and self-education for students developing an analysis of American society'; it would serve as 'an agency for integrating thought with action so as to bring about constructive changes'; and it would endeavor to provide 'a coordinating body for relating the problems of leftist students' with other interested groups on campus and in the community. The Committee, while satisfied that the statement of purposes was clear and unobjectionable on its face, exhibited concern over the relationship between the proposed local group and the National SDS organization. Ps said they would not affiliate with any national organization and that their group would remain 'completely independent.' When questioned they refused to renounce violence. The Committee ultimately approved the application and recommended to D that the organization be accorded official recognition. The majority noted and relied on the organization's claim of independence from the National SDS organization. D rejected the Committee's recommendation. D found that the organization's philosophy was antithetical to the school's policies and that the group's independence was doubtful. He concluded that approval should not be granted to any group that 'openly repudiates' the College's dedication to academic freedom. Ps filed suit seeking declaratory and injunctive relief against Ds for the denial of First Amendment rights of expression and association arising from denial of campus recognition. The judge ruled that Ps had been denied procedural due process because D had based his decision on conclusions regarding the applicant's affiliation which were outside the record before him. A hearing was held before the Dean of Students. Ps presented evidence that their organization would not associate with the national network. D reaffirmed his prior decision. The case then returned to the District Court, where it was ordered dismissed. The court concluded, first, that the formal requisites of procedural due process had been complied with, second, Ps had failed to meet their burden of showing that they could function free from the National organization, and, third, D's refusal to place its stamp of approval on an organization whose conduct it found 'likely to cause violent acts of disruption' did not violate Ps' associational rights. The appeals court affirmed. The Supreme Court granted certiorari.