Roberts v. United States Jaycees

Background

The dispute involved a national civic organization that limited regular membership to young men while offering lower-status associate memberships to women. Two Minnesota local chapters admitted women as regular members and were sanctioned by the national group. Women filed complaints under the Minnesota Human Rights Act, the state agency found discrimination, and the Minnesota Supreme Court held the Jaycees were a "place of public accommodation." The federal appeals court sided with the Jaycees, and the Supreme Court agreed to review the case.

Reasoning

The Court addressed whether forcing the organization to admit women violated members' freedom to associate or violated due process. It explained two kinds of association: intimate personal ties and expressive groups. The Jaycees’ large, unselective local chapters were not the kind of intimate groups entitled to special protection. Although the group engages in some expressive activities, the Court found Minnesota has a compelling interest in eliminating sex discrimination and that applying the law here did not unduly burden the group’s speech. The Court also rejected vagueness and overbreadth challenges because the state court used concrete criteria to decide when an organization is a public accommodation.

Real world impact

The decision lets Minnesota enforce its public accommodations law against large civic chapters that sell or recruit memberships and bars broad First Amendment immunity for such exclusionary membership rules. The practical result is that women can be admitted as full voting members of the challenged local chapters.

Dissents or concurrances

Justice O'Connor joined parts of the opinion and the judgment but emphasized a different test: she focused on whether an organization is predominantly commercial rather than predominantly expressive, and she agreed the Jaycees here were largely commercial and subject to regulation.