Lamont v. Postmaster General (1965) (Postal Service, SCOTUS)
Legal Issues
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Overview
Overview
The Court struck down a federal statute allowing the Postmaster General to block mail from communist organizations as an unconstitutional prior restraint on First Amendment rights.
The Facts
Facts
Corinne Lamont, a U.S. citizen, received mail from the Fair Play for Cuba Committee. Under 39 U.S.C. § 4001, the Postmaster General could detain mail from communist organizations unless the addressee requested delivery in writing. Lamont challenged this statutory scheme as violating her First Amendment right to receive information without government interference.
The Issue
Issue
Whether a federal statute requiring the Postmaster General to withhold delivery of foreign communist political propaganda unless the addressee affirmatively requests the materials violates the First Amendment's protection of the right to receive information.
The Rules
Rule
Lamont v. Postmaster General, 381 U.S. 301 (1965), struck down the statute as the first federal law invalidated on First Amendment grounds since the Bill of Rights was ratified. The Court held that requiring affirmative action by recipients of political correspondence as a condition of mail delivery unconstitutionally chilled the First Amendment right to receive information and ideas. A companion right to the freedom of speech and press.
The Application
Analysis
The statutory scheme unconstitutionally burdened Lamont's right to receive information by requiring her to take affirmative steps, submitting a written request, before the government would deliver communist political materials to her. This requirement created an impermissible chill on the First Amendment right to receive ideas, even though the government did not outright ban the mail, because it conditioned delivery of protected speech on the recipient's prior disclosure of interest. By placing the burden on citizens to affirmatively request delivery of disfavored foreign political materials, rather than allowing mail to flow freely and protecting national security through other means, the statute impermissibly interfered with the receipt of information as a fundamental companion to the freedoms of speech and press.
The Conclusion
Conclusion
The Court held 8-0 that the statute violated the First Amendment as an unconstitutional prior restraint on the right to receive information. The decision established that the First Amendment protects not only the right to speak but also the right to receive communications without government interference. The statute's requirement that citizens affirmatively request delivery of such mail impermissibly burdened this fundamental right.
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