This stipulation meant that all slaves and their descendants had to pass a rigorous literacy test based on knowledge of the state constitution and other highly technical documents. Few, if any, African Americans passed the test. The NAACP appointed its first African American executive director, JAMES WELDON JOHNSON (1871–1931), in 1920. Under Johnson and his successor, Walter White, who led the organization from 1931 to 1955, the NAACP worked for the passage of a federal anti- lynching law. Although unsucc essful in its efforts to pass a federal law, the NAACP brought public attention to the brutality of LYNCHING and helped to significantly reduce its occurrence. As a result, lynching (the infliction of punishment, usually by hanging, by a mob without trial) is now illegal in every state. In 1941 the NAACP established its Washington, D.C., bureau as the legislative advocacy and lobbying arm of the organization. The bureau does the strategic planning and coordination of NAACP political action and legislation program. It acts as the liaison between NAACP units and government agen- cies, and it coordinates the work of other organizations that support NAACP programs and proposals. The bureau sponsors the annua l Legislative Mobilization, which informs participants of the NAACP legislative agenda, monitors and advo- cates for NAACP civil rights and related National Association for the Advancement of Colored People 1905 W. E. B. Du Bois and others founded the Niagara Movement 1908 Race riots erupted in Springfield, Illinois, Abraham Lincoln’s hometown 1909 On 100th anniversary of Lincoln’s birthday, more than sixty citizens issued a “call” for a national conference to renew the struggle for civil and political liberty; the group and conference formed the foundation of the NAACP 1910 National Association for the Advancement of Colored People (NAACP) chosen as group’s name at second annual conference; William Walling chosen as executive director; W. E. B. Du Bois chosen as director of publicity and research and editor of the Crisis 1911 NAACP incorporated 1915 In Guinn v. United States, the Supreme Court struck down grandfather clauses in state constitutions as unconstitutional barriers to voting rights granted under the Fifteenth Amendment 1917 Supreme Court barred municipal ordinances requiring racial segregation in housing in Buchanan v. Warley 1920 NAACP appointed its first African American executive director, James Weldon Johnson 1923 Supreme Court ruled in Moore v. Dempsey that exclusion of African Americans from a jury was inconsistent with the right to a fair trial 1931 Walter White appointed to succeed Johnson as director of NAACP 1934 Charles Hamilton Houston hired as NAACP’s first full-time attorney 1936 Thurgood Marshall joined NAACP as special counsel 1940 NAACP created separate legal arm, the NAACP Legal Defense and Educational Fund, and appointed Marshall as its director-counsel 1941 Secretary of Army authorized first segregated airman unit, the 99th Squadron, better known as the Tuskegee Airmen 1948 Marshall’s team argued Shelley v. Kraemer, which struck down racially restrictive (land) covenants; President Truman abolished racial segregation in armed services by executive order 1950 In Sweatt v. Painter, Supreme Court ruled racially segregated professional schools inherently unequal and therefore unconstitutional; first integrated combat units saw action in Korea 1954 Marshall’s team argued Brown v. Board of Education of Topeka, Kansas, which ruled racial segregation in public schools unconstitutional 1955 Roy Wilkins appointed to succeed White as NAACP’s executive director 1961 Marshall appointed to U.S. Court of Appeals for the Second Circuit; Jack Greenberg succeeded Marshall as director of LDF 1964 NAACP lobbying led to passage of the Civil Rights Act of 1964 1965 NAACP lobbying led to passage of the Voting Rights Act of 1965 1967 Thurgood Marshall became first African American associate justice of the Supreme Court 1968 NAACP lobbying led to passage of the Fair Housing Act of 1968 1972 U.S. Supreme Court declared existing capital punishment laws unconstitutional in Furman v. Georgia 1974 NAACP experienced a setback when Supreme Court overturned efforts to integrate largely white suburban school districts with largely black urban districts in Milliken v. Bradley 1976 Georgia, Florida, and Texas drafted new death penalty laws; Supreme Court upheld these new laws 1977 Benjamin Hooks succeeded Wilkins as NAACP’s executive director 1978 Supreme Court placed limits on affirmative action programs in Regents of University of California v. Bakke 1993 Benjamin F. Chavis Jr. appointed to succeed Hooks as NAACP’s executive director 1994 NAACP board of directors voted to oust Chavis after sexual harassment suit was filed against him 1995 Myrlie Evers-Williams replaced William F. Gibson as chair of the NAACP board of directors 1996 NAACP board appointed Kweisi Mfume, a U.S. representative from Maryland, as president and chief financial officer; Mfume cut national staff by third as first step in returning NAACP to financial health 1997 NAACP launched the Economic Reciprocity Program 2000 TV diversity agreements; retirement of the debt and first six years of a budget surplus; largest African American voter turnout in 20 years 2001 Cincinnati riots; development of five year strategic plan 2009 NAACP celebrated its 100th anniversary SOURCE: NAACP Web pa g e, available online at http://www.naacp.or g ; Simple Justice b y Richard Klu g er (1975). ILLUSTRATION BY GGS CREATIVE RESOURCES. REPRODUCED BY PERMISSION OF GALE, A PART OF CENGAGE LEARNING. GALE ENCYCLOPEDIA OF AMERICAN LAW, 3 RD E DITION 168 NAACP legislation, and prepares an annual Report Card, showing how each member of Congress voted on key civil rights issues. For its early LITIGATION efforts, t he NA ACP relied on lawy ers w ho volunt eered their services. In 1934 the group hired CHARLES HAMILTON HOUSTON , an African American and the dean of Howard Law School, as its first full-time attorney. The following year Houston started a legal campaign to end school segregation. Houston was assisted by THURGOOD MARSHALL,ayoung lawyer who would go on to argue many cases before the Supreme Court and in 1967 become the first African American appointed to the Court. In 19 40, t he NAACP a pp ointed M arshall director-counsel of its new legal branch, the NAACP LEGAL DEFENS E AND EDUCATIONAL FUND (LDF). In 1948 Marshall, along with fellow attorneys, won a critical victory in Shelley v. Kraemer (334 U.S. 1, 68 S. Ct. 836, 92 L. Ed. 1161 [1948]), putting an end to the enforcement of racially restrictive REAL ESTATE covenants that prevented blacks from purchasing homes in white neighbor- hoods. In 1957, the LDF became a separate entity. After succeeding in Supreme Court cases concerning unequal salary scales for black teachers and segregation in graduate and professional schools, the NAACP achieved its most celebrated triumph before the Court in Brown, a decision that declared racial segrega- tion in public schools to be unconstitutional. The Brown decision sparked another civil rights initiative, the Montgomery, Alabama, bus boycott of 1955. The boycott catapulted MARTIN LUTHER KING JR . to national recognition and spurred the creation of the SOUTHERN CHRISTIAN LEADERSHIP CONFERENCE (SCLC). By the early 1960s, the SCLC, the STUDENT NONVIOLENT COORDINATING COMMITTEE (SNCC), the Congress of Racial Equality (CORE), and the NATIONAL URBAN LEAGUE all promoted civil rights for African Americans. These groups adopted a direct-action approach to promoting African American interests by conducting highly publi- cized sit-ins and demonstrations. The NAACP, meanwhile, drew criticism for its devotion to traditional legal and political means for seeking social change. ROY WILKINS, executive director of the NAACP from 1955 to 1975, voiced his preference for traditional tactics over “the kind that picks a fight with the sheriff and gets somebody’s head beaten” (Spear 1984, 7:402). Although many viewed it as overly conservative in its civil rights approach, the NAACP helped pass important civil rights legislation such as the Civil Rights Act of 1964 (42 U.S.C.A. § 2000a et seq.), the VOTING RIGHTS ACT OF 1965 (42 U.S.C.A. § 1973 et seq.), and the FAIR HOUSING ACT OF 1968 (42 U.S.C.A. § 3601 et seq.). The NAACP remained an interracial group and spurned the call for black nationalism and separatism voiced by SNCC, the Black Panthers, and other groups that turned to blacks-only membership later in the 1960s. Unlike many of the more radical civil rights groups, the NAACP outlasted the turbulent 1960s. However, it experienced setbacks during the 1970s in Supreme Court cases such as Bradley v. Millikin (418 U.S. 717, 94 S. Ct. 3112, 41 L. Ed. 2d 1069 [1974]), which overturned efforts to integrate largely white suburban public school districts and largely black urban districts, and Regents of University of California v. Bakke (438 U.S. 265, 98 S. Ct. 2733, 57 L. Ed. 2d 750 [1978]), which placed limits on AFFIRMATIVE ACTION programs. BENJAMIN L. HOOKS succeeded Wilkins as NAACP director in 1977. Hooks held that office until 1993, when he was replaced by Benjamin F. Chavis Jr. Leadership and funding problems plagued the NAACP dur ing the mid- 1990s. After a SEXUAL HARASSMENT suit was filed against Chavis in 1994, the NAACP board of directors voted to oust him as executive director. The following year, it dismissed board chairman William F. Gibson and replaced him with MYRLIE EVERS-WILLIAMS, the widow of civil rights activist MEDGAR EVERS. Seeking to put aside its troubles, on February 20, 1996, the NAACP board appo inted Kweisi Mf ume, a U.S. repre- sentative from Maryland and head of the Congressional Black Caucus, as the organiza- tion’s new president and chief executive officer. To restore the organization’s financial stability, Mfume reduced the national staff by one-third. Mfume stepped down in 2004. Among its many tasks, the NAACP works on the local level to handle cases of racial discrimi- nation; offers referral services, tutorials, and day care; sponsors the NAACP National Housing Corporation to help develop low- and moderate- income housing for families; offers programs to youths and prison inmates; and maintains a law library. It also lobbies Congress regarding the appointment of Supreme Court justices. The NAACP accepts people of all races and religions as members. In the early 2000s, it had a GALE ENCYCLOPEDIA OF AMERICAN LAW, 3RD E DITION NAACP 169 membership of more than 500,000, with 2,200 units (including more than 600 youth councils and college chapters) in the United States and around the world. The organization continues to struggle with the need to increase membership and retain relevancy while advocating for various civil rights issues. In 2000 the board instituted mandatory training for NAACP local leadership. More than 10,000 branch officers and executive committee members attended the training, and the organization removed 800 officers and committee members who did not attend. The NAACP has also taken steps to build coalitions with black youth. Former NAACP president Kweisi Mfume sat on the board of Summit Action Network, a coalition of hip hop music stars as well as record company execu- tives and community organizations that seek to educate and mobilize fans of rap music to register and vote in local and national elections. In addition, the NAACP has sought to over- come political differences and gain the support of the country’s major Latino civil right organizations, including the LEAGUE OF UNITED LATIN AMERICAN CITIZENS (LULAC) and the NATIONAL COUNCIL OF LA RAZA. In January 2003, the NAACP announced that the UNITED NATIONS had designated it as a non-governmental organization (NGO). The NGO designation meant that the NAACP could advise and consult with foreign governments and with the U.N. secretariat on issues relating to HUMAN RIGHTS . In May 2008 the NAACP selected Benjamin T. Jealous, an activist and former news execu- tive, to serve as president and CEO of the organization. At 35, Jealous was the youngest leader in the organization’s history. In February 2009, the NAACP celebrated its 100th anniver- sary, amidst ongoing debate over whether the organization remained necessary in the modern world. Although some argued that the organi- zation had become irrelevant, citing the election of BARACK OBAMA as the first African American U. S. president, Jealous urged otherwise. The NAACP centennial convention turned its focus to addressing the modern issues of predatory lending and AIDS, and Jealous promised to focus on ongoing human rights issues during his term. FURTHER READINGS NAACP. Available online at www.naacp.org (accessed September 16, 2009). Rhym, Darren. 2002. The NAACP. Philadelphia: Chelsea House. Schneider, Mark R. 2002. We Return Fighting: The Civil Rights Movement in the Jazz Age. Boston: Northeastern Univ. Press. Sullivan, Patricia. 2009. Lift Every Voice: The NAACP and the Making of the Civil Rights Movement. New York: New Press. CROSS REFERENCE Discrimination. NAACP LEGAL DEFENSE AND EDUCATIONAL FUND In 1940, the organization formerly known as the National Association for the Advancement of Colored People and now called the NAACP launched the Legal Defense and Educational Fund (LDF). Since its founding, the LDF has been involved in more cases before the U.S. Supreme Court than any other nongovernmen- tal organization. The National Association for the Advance- ment of Colored People (NAACP), which had been founded in 1909 to support civil rights, soon found itself needing direction and aid as it sought to help people find their way through the criminal justice system. Under the leader- ship of future Supreme Court Justice THURGOOD MARSHALL , the Legal Defense and Educational Fund (LDF) was created to provide information about the criminal justice system and legal assistance to indigent African Americans. In 1957, three years after the Supreme Court’s landmark decision in BROWN V. BOARD OF EDUCATION OF TOPEKA , KANSAS (347 U.S. 483, 47 S. Ct. 686, 98 L. Ed. 873), which held that SEGREGATION in public schools was unconstitu- tional, the LDF was established as an entirely separate organization from the NAACP. The LDF is headquartered in New York City and has regional offices in Washington, D.C., and Los Angeles. The LDF has close to two dozen attorneys on staff whose work is supplemented by assistance from hundreds of attorneys around the United States. The LDF primarily works with issues involving education, AFFIRMATIVE ACTION,fair employment and economic access, issues re- lated to voting and other forms of civic and political participation, and criminal justice issues, including the death penalty and prison reform. With more than 100 active cases, the GALE ENCYCLOPEDIA OF AMERICAN LAW, 3RD E DITION 170 NAACP LEGAL DEFENSE AND EDUCATIONAL FUND LDF has one of the largest legal caseloads of any public service organization in the country. In 2007 John Payton, an attorney well known for his successful record in important CIVIL RIGHTS LITIGATION, was named director- counsel and president of the LDF. In May 2008 Payton was named one of the “Most Influential Minority Lawyers in America” by the National Law Journal. At the time of his appointment, his accomplishments were said to make him well suited to follow in the footsteps of THURGOOD MARSHALL, also a former director-counsel of the LDF. While the primary focus of the LDF is on court cases, the fund also monitors legislation, provides advocacy, education research, and builds coalitions with related organizations. The scope of LDF activity has also widened to include advocacy for other minorities in this country as well as for global HUMAN RIGHTS. To this end, the LDF has aided in the establishment of similar organizations that advocate for other minority groups in the United States. Additionally, the fund has used its experience and legal expertise to help form public-interest legal organizations in Brazil, Canada, and South Africa. In addition to the Brown case, which resulted in a flood of legal cases around the country relating to SCHOOL DESEGREGATION, the LDF won a number of significant cases in the 1950s that concerned housing DISCRIMINA- TION , voting access, jury selection, the use of forced confessions, and access to counsel by indigent persons. In the 1960s the LDF provided counsel for MARTIN LUTHER KING JR. and other civil rights activists. The LDF also began its drive to abolish CAPITAL PUNISHMENT. LDF provided counsel in numerous death penalty cases and was able to stop executions in the United States between 1966 and 1978. Since 1965 the LDF has published Death Row USA, a list of death-row inmates. In 2008 the LDF continued its fight against capital punishment, winning a life sentence for a mentally retarded man who had been on Pennsylvania’s Death Row for 26 years. Over time, LDF has also fought for the rights of indigent defendants to obtain adequate LEGAL REPRESENTATION.InRichmond v. District Court of Maryland, a 2008 action that chal- lenged the practice of the city of Baltimore in not providing indigent defendants with legal counsel upon their first appearance in court. LDF filed a FRIEND OF THE COURT brief. In its brief, LDF argued that the relevant law obligates the appointment of counsel at the initial appearance stage of the proceedings. In the 1980s and 1990s the LDF undertook hundreds of CLASS ACTION suits against employ- ers, unions, and governmental units that have helped secure and safeguard the employment rights of thousands of workers. The LD F also continued to support major voting rights legislation and to be involved in numerous cases aimed at securing voting rights for minorities. In the early 2000s the LDF continued to be involved in cases stemming from the redistricting of congressional districts after the 2000 census. After the 2000 presiden- tial election, the LDF and five other civil rights organizations filed a class action lawsuit against Florida’s SECRETARY OF STATE and other elected officials, alleging that a significant number of minority citizens were unable to vote or faced severe obstacles in trying to register and vote. Prior to the 2008 presidential election, the LDF unveiled a campaign called Prepared to Vote, which was designed to augment tradi- tional voter participation efforts by providing critical election information to minority communities. The program components include community–based workshops, the distribution of community-friendly materials, meetings with election officials, and an educational Website. The LDF created the Prepare to Vote campaign to ensure that the voting process is administered uniformly and fairly in minority communities. The LDF has likewise fought in support of equal education and affirmative action. In February 2003, the LDF filed briefs in two major suits that challenged the use of race- conscious criteria in the admissions programs of the University of Michigan law school and its undergraduate School of Literature, Science, and the Arts. The Supreme Court ultimately decided in favor of the University of Michigan race-conscious criteria for admissions (Grutter v. Bollinger, ____ U.S., ____, 123 S. Ct. 2235, ___ L. Ed. 2d ____ [U.S., Jun 23, 2003]). As of 2010 the LDF cont in ued its fight i n support of affi- rmative action, battling against a nti-affirmative action ballot initiatives in five states. FURTHER READINGS Greenberg, Jack. 1994. Crusaders in the Courts: How a Dedicated Band of Lawyers Fought for the Civil Rights Revolution. New York: BasicBooks. GALE ENCYCLOPEDIA OF AMERICAN LAW, 3RD E DITION NAACP LEGAL DEFENSE AND EDUCATIONAL FUND 171 Kluger, Richard. 2004. Simple Justice: The History of Brown v. Board of Education and Black America’s Struggle for Equality. Rev. ed. New York: Knopf. Orfield, Gary, Susan E. Eaton, and Elaine R. Jones. 1997. Dismantling Desegregation: The Quiet Reversal of Brown v. Board of Education. New York: New Press. NAACP Legal Defense and Educational Fund. Available online at www.naacpldf.org (accessed September 16, 2009). Schwartz, Bernard. 1986. Swann’s Way: The School Busing Case and the Supreme Court. New York: Oxford Univ. Press. CROSS REFERENCES Civil Rights Acts; Equal Protection; NAACP. v NADER, RALPH Considered the father of the CONSUMER PROTEC- TION movement, Ralph Nader has had a great effect on U.S. law and PUBLIC POLICY of the late twentieth century. Nader’s advocacy on behalf of consumers and workers hastened into reality many features of the contemporary political landscape. The work of this lawyer and irrepressible gadfly of the powers that be, which began in the mid-1960s, has led to the passage of numerous consumer-protection laws in such areas as automobiles, mining, insurance, gas pipelines, and meatpacking, as well as the creation of government agencies such as the National Highway Traffic Safety Administra- tion, the Occupational Safety and Health Administration, the ENVIRONMENTAL PROTECTION AGENCY , and the CONSU MER PRODUCT SAFETY COMMISSION . Nader himself has founded many well-known consumer advocacy groups, includ- ing the PUBLIC INTEREST Research Group, the Clean Water Action Project, the Center for Auto Safety, and the Project on Corporate Responsi- bility. His goal in these efforts, he has said, is “nothing less than the qualitative reform of the industrial revolution.” Nader was born February 27, 1934, in Winsted, Connecticut, to Nadra Nader and Rose Bouziane Nader, Lebanese immigrants who owned and operated a restaurant and bakery. He is the youngest of five children. He attended the Gilbert School and Princeton University on scholarships. At Princeton he entered the WOODROW WILSON School of Public and Interna- tional Affairs, and he graduated magna cum laude and Phi Beta Kappa in 1955. During an era of conformity, his challenges to school authorities and procedures at Princeton made him stand out. At one point, he protested the use of the poisonous insecticide dichlorodipehnyl- trichloroethane (DDT) on campus trees. After Princeton, Nader attended Harvard Law School, where he edited the Harvard Law Record, and graduated with distinction in 1958. It was at Harvard that he first became interested in auto safety. After studying auto-injury cases, in 1958 he published his first article on the subject, “American Cars: Designed for Death,” in the Harvard Law Record. It contained a thesis that he would bring to national attention in the mid-1960s: Auto fatalities result not just from driver error, as the auto industry had main- tained, but also from poor vehicle design. Nader followed his law degree with six months of service in the Army and then a period of personal travel through Latin America, Europe, and Africa. Upon his return, he established a Ralph Nader 1934– ▼▼ ▼▼ 2000 1975 1950 ❖ ◆ 1939–45 World War II 1934 Born, Winsted, Conn. 1950–53 Korean War 1961–73 Vietnam War ◆ ◆◆ ◆ ◆ 1958 Published first article on auto injury cases, in the Harvard Law Record; earned LL.B. from Harvard Law School 1964–65 Served as consultant at Labor Department ◆ 1965 Unsafe at Any Speed published ◆ ◆ ◆ ◆◆ 1966 Highway Safety Act and National Traffic and Motor Vehicle Safety Act passed by Congress 1967 Initiated publicity campaign that helped pass the Wholesome Meat Act 1971 Founded Public Citizen Foundation ◆ 1969 Founded the Center for the Study of Responsive Law 1972 Congress created Consumer Product Safety Commission 1970 Occupational Safety and Health Administration and Environmental Protection Agency created by acts of Congress 1988 Helped win California referendum mandating auto insurance rate rollbacks; helped block proposed congressional pay raise 1992 Ran for president as independent 2002 Crashing the Party published 2000 Cutting Corporate Welfare published; ran for president on the Green Party platform ◆ 1996 Ran for president on the Green Party platform; No Contest published 2004 Ran for president as independent ◆ 2007 The Seventeen Traditions published ◆ 2008 Ran for president as independent GALE ENCYCLOPEDIA OF AMERICAN LAW, 3RD E DITION 172 NADER, RALPH PRIVATE LAW practice in Hartford, Connecticut created an informal legal aid society, and lectured from 1961 to 1963 at the University of Hartford. Having worked at the local level for auto- safety regulations in the years subsequent to his graduation from Harvard, Nader decided to go to Washington, D.C ., in 1964, where he hoped to have more influence. Through his friendship with Daniel P. Moynih an, who then was serving as assistant secretary of labor, Nader worked as a consultant at the DEPARTMENT OF LABOR and wrote a study that called for federal responsibil- ity over auto safety. Nader left the Department of Labor in May 1965 and devoted himself to completing what would become his most celebrated book, Unsafe at Any Speed: The Designed-in Dangers of the American Automobile. The book was published later that year and quickly became a best-seller. In it, Nader painted a grim picture of motor vehicle injuries and fatalities, noting that 47,700 people were killed in auto accidents in 1964. He made an eloquent appeal for federal car-safety standards that would both prevent accidents from occurring and better protect passengers in the event of an accident. The book also communicated a philosophy regarding public regulation of technology that would cause him to do battle on many other issu es. “A great problem of contemp orary life,” he wrote, “is how to control the power of economic interests which ignore the harmful effects of their applied science and technology.” Nader has devoted his life to solving this problem. Taking some of his inspiration from the CIVIL RIGHTS MOVEMENT, Nader stood up to the most powerful companies in the world. His book targeted the safety problems of the Chevrolet Corvair, a product of the world’s largest company, General Motors (GM). He convincingly marshaled evidence that the driver could lose control of the Corvair even when it was moving slowly, thus makin g it “unsafe at any speed.” The Goliath GM did not take kindly to the stones thrown by this David, and the company began a campaign of harassment and intimidation that was intended to abort Nader’s efforts. Subsequent congressional committee hearings in 1966 revealed that GM’s campaign against Nader had involved harassing phone calls and attempts to lure Nader into compromising situations with women. The company formally apologized before Congress for these tactics. Many politicians in Washington, D.C., and many Americans were receptive to Nader’s ideas. In 1966, in his State of the Union address, President LYNDON B. JOHNSON called for a national highway safety act. Later that year, Congress passed the Highway Safety Act (80 Stat. 731 [23 U.S.C.A. § 401 note]) and the National Traffic and Motor Vehicle Safety Act (80 Stat. 718 [15 U.S.C.A. § 1381 note]). The latter created a new government body, later named the National Highway Traffic Safety Adminis- tration, that oversaw the creation of federal safety standards for automobiles and was also empow- ered to authorize recalls of unsafe vehicles. In subsequent years, these laws and others for which Nader had advocated helped to bring about a marked decrease in traffic fatalities per vehicle mile. As the Washington Post exclaimed, on August 30, 1966, “[A] one-man lobby for the public prevailed over the nation’s most power- ful industry.” Nader’s first work in the area of auto safety remains his most famous consumer advocacy. However, he has remained a tireless propon ent of consumers’ and workers’ rights on many different fronts. Shortly after his triumph with auto regulation, Nader initiated a publicity campaign that helped to pass the Wholesome Ralph Nader. AP IMAGES THE MOST IMPORTANT OFFICE IN AMERICA FOR ANYONE TO ACHIEVE IS FULL -TIME CITIZEN. —RALPH NADER GALE ENCYCLOPEDIA OF AMERICAN LAW, 3RD E DITION NADER, RALPH 173 Meat Act, 81 Stat. 584, 19 U.S.C.A. 1306 (1967), which established stricter federal guidelines for meatpacking plants. By the late 1960s he began to mobilize college students who joined him in his investigations of public policy and the effectiveness of governme nt regulations. These young forces came to be called “Nader’s Raiders,” and many of them eventually rose to positions of influence in the government and in public policy organizations. By the mid-1970s, the various groups that Nader had created, including Public Interest Research Groups in many states, were doing research and financing legal action in relation to myriad public policy issues, including tax reform, consumer-product safety, and corporate responsibility. During Ronald Reagan’s presidency in the 1980s, Nader’s influence in Washington, D.C., declined, particularly as the Reagan administra- tion dismantled much of the government regulation that Nader had helped to establish. He did not give up his cause, however. In the late 1980s, he was again in the media spotlight, this time through his attempts to lower car- insurance rates in California and to block a proposed congressional pay increase. During the 1980s and 1990s, he also addressed the savings- and-loan bailout problem, well before it became high on the nation’s agenda; opposed the use of chlorofluorocarbons (CFCs), which damage the ozone layer; and worked to prevent limitations on damages that consumers may receive from corporations through civil lawsuits. Nader has run for president in every presidential election from 1992 to 2008. In 1992, he entered the race as a write-in candidate. Four years later, he was nominated as a candidate by the GREEN PARTY,whichhasitsstrongest support in California. With political activist Winona LaDuke as his running mate, he ran a no-frills campaign, accepting no taxpayer money, eschewing advertising, and often traveling alone. He earned 684,902 votes that year, including two percent of the votes in California. Nader ran again in the 2000 election. He raised more than $8 million for the campaign, some $30 million less than REFORM PARTY candi- date PAT BUCHANAN. Running again wi th LaDuke, Nader finished third in the election, with 2,882,955 votes, while Buchanan finished with 448,895. Several supporters urged Nader to run again in the 2004 election, which he did. That time, the support that had carried him through the previous election was non-existent as many called for him to rem ove himself from the running. Nader ran for president again in 2008 as an independent and received 0.6% of the votes. Nader has written and edited dozens of books during his career, including Crashing the Party, which details his run during the 2000 presidential election. Other books include The Consumer and Corporate Accountability (1973), Corporate Power in America (1973), Working on the System: A Comprehensive Manual for Citizen Access to Federal Agencies (1974), Government Regulation: What Kind of Reform? (1976), The Big Boys: Power and Position in American Business (1986), and Collision Course: The Truth about Airline Safety (1994). FURTHER READINGS Herrnson, Paul S., and John C. Green, eds. 1998. Multiparty Politics in America. Lanham, Md.: Rowman & Littlefield. Martin, Justin. 2002.Nader: Crusader, Spoiler, Icon. Cambridge, Mass.: Perseus. Nader, Ralph. 2007. The Seventeen Traditions. New York: HarperCollins. ———. 2002. Crashing the Party: Taking on the Corporate Government in an Age of Surrender. New York: Thomas Dunne Books/St. Martin’s Press. ———. 2000. The Ralph Nader Reader. New York: Seven Stories Press. ———. 1972. Unsafe at Any Speed: The Designed-in Dangers of the American Automobile. Rev. ed. New York: Grossman. Nader, Ralph, and Wesley J. Smith. 1996. No Contest: Corporate Lawyers and the Perversion of Justice in America. New York: Random House. CROSS REFERENCE Green Party. NAFTA See NORTH AMERICAN FREE TRADE AGREEMENT. NAKED CONTRACT From the Latin term nudum pactum, or “bare agreement.” An agreement between two parties that is without any legal effect because no consideration has been exchanged between the parties. A naked contract, also known as a “nude contract,” is unenforceable in a court of law. In ROMAN LAW, a nudum pactum was an informal agreement that was not legally en- forceable, because it did not fall within the specific classes of agreements that could support a legal action. A pactum could, however, create an exception to or modification of an existing obligation. GALE ENCYCLOPEDIA OF AMERICAN LAW, 3RD E DITION 174 NAFTA NAME The designation of an individual person or of a firm or corporation. A word or combination of words used to distinguish a person, thing, or class from others. An individual’s name comprises a name given at birth, known as the given name or first name, selected by the parents, and the surname or last name, which identifies the family to which he or she belongs. Ordinarily an individual is not properly identified unless he or she is called or described by this given name in addition to the surname. This rule has significance, among other times, when students are designated in school records and when parties are called or referred to in LEGAL PROCEEDINGS , in cluding CHILD CUSTODY actions. The general rule is that when identity is certain, a small variance in name, such as that caused by typographical errors, is unimportant. The method by which an individual can change his or her name is usually prescribed by state statutes and involves filing a certificate in, or making an application to, a court. Whether or not a name change will be granted is ordinarily a matter of judicial di scretion. In more recent times, more states have moved away from this and allowed name changes reg ardless of reason. In recent years, married women have begun to depart from the traditional practice of taking their husband’s surname upon marriage. In- stead they retain their birth names, the surnames possessed before marriage. All 50 states now allow a wife to keep her birth nam e or use her husband’s surname. In addition, several states now recognize the rights of women in choosing names for their children. Interestingly, the majority of states do not give statutory authority for a husband to adopt his wife’s surname. FURTHER READING Frandina, Michael Mahoney. 2009. “AMan’s Right to Choose His Surname in Marriage: A Proposal.” Duke Journal of Gender Law & Policy (January), 155. NAPOLEONIC CODE The first modern organized body of law governing France, also known as the Code Napoleon or Code Civil, enacted by Napoléon I in 1804. In 1800 Napoléon I appointed a commis- sion of four persons to undertake the task of compiling the Napoleonic Code. Their efforts, along with those of J. J. Cambacérès, were instrumental in the preparation of the final draft. The Napoleonic Code assimilated the private law of France, which was the law governing transactions and relationships be- tween individuals. The Code, which is regarded by some commentators as the first modern counterpart to ROMAN LAW, is currently in effect in France in an amended form. The Napoleonic Code is a revised version of the Roman law or CIVIL LAW, which predomi- nated in Europe, with numerous French modifications, some of which were based on the Germanic law that had been in effect in northern France. The code draws upon the Institutes of the Roman CORPUS JURIS CIVILIS for its categories of the civil law: property rights, such as licenses; the acquisition of property, such as trusts; and personal status, such as legitimacy of birth. Napoléon applied the code to the territories he governed—namely, some of the German states, the low countries, and northern Italy. It was extremely influential in Spain and, eventu- ally, in Latin America as well as in all other European nations except England, where the COMMON LAW, also known as judge-made law, prevailed. It was the harbinger, in France and abroad, of codifications of other areas of law, such as CRIMINAL LAW, CIVIL PROCEDURE , and COMMERCIAL LAW. The Napoleonic Code served as the prototype for subsequent co des during the nineteenth century in 24 countries; the province of Québec and the state of Louisiana have derived a substantial portion of their laws from it. (The other 49 states in America follow the common law tradition.) Napoléon also promulgated four other codes: the Code of Civil Procedure (1807), the Commercial Code (1808), the Code of Criminal Procedure (1811), and the Penal Code (1811). NARAL PRO-CHOICE AMERICA NARAL Pro-Choice America, founded in 1969 as the National ABORTION and Reproductive Rights Action League, is a nonprofit organiza- tion that was formed primarily to maintain a woman’s LEGAL RIGHT to have an abortion. The mission of NARAL, however, has broadened to include supporting policies that enable women GALE ENCYCLOPEDIA OF AMERICAN LAW, 3RD E DITION NARAL PRO-CHOICE AMERICA 175 and me n to make responsible decisions about sexuality, contraception, pregnancy, childbirth, and abortion. NARAL is comprised of a network of 35 state affiliates and has 500,000 members. It has proven to be an effective organization, promoting pro-choice candidates for state and federal offices and LOBBYING for pro-choice legislation. Since the U.S. Supreme Court legalized abortion in ROE V. WADE, 410 U.S. 113, 93 S. Ct. 705, 35 L. Ed. 2d 147 (1973), opponents of abortion have sought to overturn or limit this decision. NARAL has vigo rously defended Roe but has also encouraged better sex education and the use of birth control to make abortion necessary less often. Through NARAL Pro- Choice America PAC, its political action committee, NARAL has been a driving force behind the election of many pro-choice candi- dates. NARAL Pro-Choice America PAC mounts campaigns to elect pro-choice candi- dates and defeat candidates opposed to legalized abortion, using paid advertising and get-out- the-vote efforts. It also persuaded the Wal-Mart and Kroger Corporations to cease blocking women’s access to emergency contraception. The NARAL Pro-Choice America Founda- tion, a charitable organization founded in 1977, supports research and legal work, publishes substantive policy reports, mounts public edu- cation campaigns and other communications projects, and provides leadership training for grassroots activists. The NARAL Foundation and NARAL employ a computerized state-by- state database, NARAL*STAR (State Tracking of Abortion Rights), which provides up-to-the- minute information for NARAL staff, affiliates, policy makers, media, and coalition partners on state laws related to reproductive rights, pend- ing legislation, state constitutions, and state executive branches. Since 2005 the organization has helped defeat seven anti-choice ballot measures in four states. NARAL and the NARAL Foundation regu- larly publish Who Decides? A State-by-State Review of Abortion Rights, a compilation of abortion-related information in each state, including the position on choice of elect ed officials, summaries of selected statutes and regulations, and recent legislative activity. NARAL worked with the Clinton adminis- tration to reverse policies of the Reagan and GEORGE H.W. BUSH administrations dealing with abortion. It helped remove bans on the testing of RU-486 (a nonsurgical abortion method), the use of fetal tissue in scientific research, and the provision of abortion services at military hospitals. NARAL also played a major role in the passage of the Freedom of Access to Clinic Entrances Act, which places certain restrictions on protestors’ ability to obstruct or hinder persons seeking access to abortion services. Since 1996, when Congress enacted a bill banning the practice of partial-birth abortions, NARAL has been on the defensive. Though President BILL CLINTON vetoed the bill, many states have since passed laws banning the procedure, and Congress continues to debate the issue. The election of GEORGE W. BUSH as presi dent in 2000, and the gain of Republ ican seats in both the House an d Senate in 2002, strength- ened the position of a bortion opponents and gave increased urgency to the NARAL pro- choice mission. NARAL helped block the appointment of Bush’s anti-choice nominee Richard Honaker to the federal bench. The organization continues to fight for increased access to federal funding of abortions for poor women, federal employees, and women in the military. It has mounted vigorous campaigns opposing President Bush’s judicial no minees whoareopposedtoabortion.Theorganiza- tion also launched “Generation Pro-Choice,” a Web site aimed at educating college students and younger women about their reproductive rights and encouraging them to become pro- choice advocates. Since 2006 it has been instrum ental in electing 44 new pro-ch oice members of the House and nine pro-choice senators, and supported Barack Obama’sbid for the presidency. FURTHER READING NARAL. 2009. “How We Win.” Available online at http:// www.prochoiceamerica.org/about-us/how -we-win/; website home page: http://www.prochoiceamerica.org/ (accessed August 5, 2009). CROSS REFERENCES Abortion; Fetal Rights; Women’s Rights. NARCOTICS ACTS Control over, and prevention of, the distribution and usage of narcotic drugs has been a maj or priority of the federal government and the various state governments since the early part of the GALE ENCYCLOPEDIA OF AMERICAN LAW, 3RD E DITION 176 NARCOTICS ACTS twentieth century. Notwithstanding these efforts, statistics on the use of narcotics in the United States remain startling. They encompass not only the trafficking and arrests associated with illegal substances, but also the vast numbers associated with illegal trafficking of legal prescription medications. In the new millennium, the exposure of rampant use of anabolic steroids has put new burdens on enforcement activities because these substances are often found in non-prescription dietary supplements formerly not subject to control or inspection. Background In any given year, the number of arrests and convictions associated with the trafficking of drugs remains startling. The Justice Department’s DRUG ENFORCEMENT ADMINISTRATION (DEA), tasked with oversight, announced that in 2008 alone, it had made 26,425 domestic arrests involving a cumulative figure of over nine million halluci- nogenic dosage units in drug seizu res. (This figure actually represented a decrease in arrests from the 29,097 reported for 2007.) The four major drug classifications involved in the 2008 statistics were cocaine (49,823 kilograms seized); heroin (598.6 kilograms seized); marijuana (660,969 kilograms seized); and methamphet- amine (1,540 kilograms seized). According to the National Household Drug Survey on Drug Abuse, conducted by the SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES ADMINISTRATION , 55.6 percent of respondents between the ages of 18 and 25 said that they had used illicit drugs. This compares to 53.3 percent of respondents between the ages of 26 and 34, and 28.4 percent of respondents between the ages of 12 and 17. The National Institute on Drug Abuse’s 2002 Monitoring the Future Study found that 53 percent of high-school seniors claimed to have used narcotics, including 41 percent who said that they had used drugs in the past year, and 25.4 percent who said that they had used drugs in the past month. The efforts of law enforcement officers have had some effect on the use and transfer of narcotics in the past, although these efforts have been costly. In 2001 federal agents seized approximately 1,215 metric tons of marijuana, 106 metric tons of cocaine, 3.6 metric tons of methamphetamine, and 2.5 metric tons of heroin. The costs to society of enforcing narcotics laws have continued to increase. In 1992 the total estimated costs to society of narcotics use was $102 billion. By 2000 this number had grown to $160 billion, including almost $15 billion in health care costs. Development of Federal Narcotics Laws During the Civil War, forms of opiates were considered “miracle” drugs that could be used as anesthetics when a doctor performed surgery. Without opiates, surgeries during that period, which often consisted of amputations, involved a group of men holding down a patient while a doctor sawed off the limb of a patient. By the 1870s, opiates, cocaine, and other drugs were used in a variety of medical concoctions, leading to increases in addictions. The use of opium, cocaine, and other drugs continued through most of the nineteenth century. The type of addiction during that time that caused the most concern was alcoholism, and because the causes of addiction and the dangers of narcotics were both unknown, doctors recommended morphine and heroin as remedies for addiction to alcohol. Cocaine was also used in tonics, such as the first form of the mixture that became known as Coca-Cola. Moreover, patients, including those of Sigmund Freud, were treated for depression with cocaine. Congress enacted the PURE FOOD AND DRUG ACT OF 1906 , ch. 3915, 34 Stat. 768, which formed the FOOD AND DRUG ADMINISTRATION (FDA) and gave it the power to regulate food and drugs. Drug addiction began to drop as a result of early FDA regulations. Eight years later, Congress enacted the Harrison Tax Act, ch. 1, 38 Stat. 789, which prohibited the dispensation and distribution of narcotic drugs. In 1922, Con- gress enacted the Narcotics Drug Import and Export Act, ch. 202, 42 Stat. 596, which prohibited importation and use of opium and other narcotics except for medical purposes. Between 1922 and 1970 Congress enacted several additional laws that were designed to curb narcotics importation, trade, and use. Drugs such as marijuana and heroin were prohibited, as was the cultivation of opium poppies. The Narcotic Control Act of 1956, ch. 629, 70 Stat. 567, criminalized the transport of narcotics, including marijuana. Some legisla- tion began to focus upon rehabilitation of narcotics addicts. For example, the Narcotic Addict Rehabilitation Act of 1966, Pub. L. No. 89-793, 80 Stat. 1438, provided for treatment of addicts as an alternative to INCARCERATION. GALE ENCYCLOPEDIA OF AMERICAN LAW, 3RD E DITION NARCOTICS ACTS 177 . modification of an existing obligation. GALE ENCYCLOPEDIA OF AMERICAN LAW, 3RD E DITION 174 NAFTA NAME The designation of an individual person or of a firm or corporation. A word or combination of words. a Dedicated Band of Lawyers Fought for the Civil Rights Revolution. New York: BasicBooks. GALE ENCYCLOPEDIA OF AMERICAN LAW, 3RD E DITION NAACP LEGAL DEFENSE AND EDUCATIONAL FUND 171 Kluger, Richard as independent ◆ 20 07 The Seventeen Traditions published ◆ 2008 Ran for president as independent GALE ENCYCLOPEDIA OF AMERICAN LAW, 3RD E DITION 172 NADER, RALPH PRIVATE LAW practice in Hartford,