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statuteobjection
statuteappealobjectionappellee

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Wooley v. Maynard, 430 U.S. 705, 97 S.Ct. 1428, 51 L.Ed.2d 752

Facts

The case involves George Maynard and his wife, who are followers of the Jehovah's Witnesses faith and find the New Hampshire state motto 'Live Free or Die' objectionable. They covered the motto on their vehicle license plates and were subsequently prosecuted under a state statute making it a crime to obscure the motto. After multiple prosecutions and a brief jail sentence for Maynard, they sought declaratory and injunctive relief in federal court against the enforcement of the statute, arguing it violated their First Amendment rights.

Appellees George Maynard and his wife Maxine are followers of the Jehovah's Witnesses faith. The Maynards consider the New Hampshire State motto to be repugnant to their moral, religious, and political beliefs, and therefore assert it objectionable to disseminate this message by displaying it on their automobiles.

Issue

Whether the State of New Hampshire may constitutionally enforce criminal sanctions against persons who cover the motto 'Live Free or Die' on passenger vehicle license plates because that motto is repugnant to their moral and religious beliefs.

The issue on appeal is whether the State of New Hampshire may constitutionally enforce criminal sanctions against persons who cover the motto 'Live Free or Die' on passenger vehicle license plates because that motto is repugnant to their moral and religious beliefs.

Rule

The First Amendment protects individuals from being compelled to express ideological messages they find objectionable. A state may not require individuals to display a state motto on their private property in a manner intended for public observation, as this infringes upon their freedom of thought and expression. The state must demonstrate a compelling interest to justify such requirements, which must not broadly stifle fundamental personal liberties.

The State may not constitutionally require an individual to participate in the dissemination of an ideological message by displaying it on his private property in a manner and for the express purpose that it be observed and read by the public. U.S.C.A.Const. Amend. 1.

Analysis

The court found that the New Hampshire statute forced individuals to act as instruments for promoting a state message they found unacceptable, thus infringing on their First Amendment rights. The state's interests in vehicle identification and promoting state pride were deemed insufficient to outweigh the individuals' rights to refrain from expressing an ideological message. The court emphasized that the right to speak and the right to refrain from speaking are complementary components of individual freedom.

The District Court held that by covering up the state motto 'Live Free or Die' on his automobile license plate, Mr. Maynard was engaging in symbolic speech and that 'New Hampshire's interest in the enforcement of its defacement statute is not sufficient to justify the restriction on (appellee's) constitutionally protected expression.' 406 F.Supp., at 1389.

Conclusion

The Supreme Court affirmed the district court's ruling that New Hampshire could not constitutionally require individuals to display the state motto on their vehicle license plates.

We conclude that the State of New Hampshire may not require appellees to display the state motto upon their vehicle license plates; and, accordingly, we affirm the judgment of the District Court.

Who won?

The Maynards prevailed in their case against the State of New Hampshire. The court ruled that the enforcement of the statute violated their First Amendment rights, allowing them to cover the state motto on their license plates without fear of prosecution. The court recognized the significant burden placed on the Maynards by the threat of repeated prosecutions, which justified the need for injunctive relief.

The court recognized that the threat of repeated prosecutions in the future against both appellees, and the effect of such a continuing threat on their ability to perform the ordinary tasks of daily life which require an automobile, is sufficient to justify injunctive relief.

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