Board of Directors of Rotary International v. Rotary Club of Duarte

Background

The dispute began when the Duarte Rotary Club in California admitted three women to full membership and Rotary International revoked the club’s charter. The women and the local club sued under California’s Unruh Civil Rights Act — the state law that bans discrimination by business establishments — seeking to stop Rotary from enforcing its male‑only rule in California and to have the club’s charter restored. A trial court sided with Rotary, finding the clubs were not business establishments, but the California Court of Appeal reversed and ordered the Duarte Club reinstated and the gender restriction blocked.

Reasoning

The Supreme Court applied the framework from Roberts v. United States Jaycees and analyzed two kinds of association: intimate private relationships and groups that associate to express ideas. The Court found local Rotary Clubs are large, open, service‑focused organizations with classification systems, publications, conferences, and frequent visitors, not intimate private groups. Evidence showed women already attend meetings and take part in activities. The Court concluded admitting women would not significantly interfere with the clubs’ expressive activities. Because California’s Unruh Act is viewpoint-neutral and serves the state’s compelling interest in eliminating sex discrimination, the Court held application of the law to California Rotary Clubs does not violate the First Amendment.

Real world impact

The ruling requires California Rotary Clubs to admit qualified women members and restores the Duarte Club’s status in Rotary International within California. The decision is limited to California’s courts and statutes, but it makes clear that state anti‑discrimination laws may be applied to similar civic organizations when membership rules are challenged on free‑association grounds.