CAMERON v. JOHNSON (1968)

Legal Principle at Issue

Whether Mississippi's Anti-Picketing Law, which prohibited picketing that obstructed or unreasonably interfered with free ingress or egress to state property and courthouses, was unconstitutionally vague and overbroad. Additionally, whether appellants are entitled to a federal injunction to block state criminal prosecutions, based on allegations that the statute was selectively enforced in bad faith to suppress peaceful civil rights protests.

Action

Affirmed (includes modified). Petitioning party did not receive a favorable disposition.

Facts/Syllabus

To protest racial voting discrimination and encourage Negro registration, Appellants picketed the Forrest County, Mississippi, voting registration office in the county courthouse each weekday from January 23 to May 18, 1964, walking in a "march route" set off by the sheriff with barricades to facilitate access to the courthouse. On April 8, the legislature enacted the Mississippi Anti-Picketing Law, which, as amended, prohibited "picketing . . . in such a manner as to obstruct or unreasonably interfere with free ingress or egress to and from any county . . . courthouses." On April 9, the sheriff read the new law to the protesters, ordered them to disperse, and removed the barricades. When the pickets the next morning resumed marching along the now unmarked route, they were arrested for violating the Anti-Picketing statute. Other arrests were made that, afternoon, on April 11, and on May 18. 

On April 13, Appellants brought this action seeking a judgment declaring that the Anti-Picketing Law is an invalid regulation of expression because of overbreadth and vagueness and an injunction against its enforcement in the prosecutions against them. Appellants contend  the prosecutions were solely to discourage their freedom of expression. Following initial dismissal of the complaint by the U.S. District Court for the Southern District of Mississippi and the Supreme Court's remand in Cameron v. Johnson (1965) for reconsideration in the light of the intervening decision in Dombrowski v. Pfister (1965), an evidentiary hearing was held, and the District Court again dismissed the complaint, holding  the statute was not void on its face and that Appellants had failed to show sufficient irreparable injury to warrant injunctive relief.