Roberts v. United States Jaycees

Rule of Law:

A state's compelling interest in eradicating gender discrimination justifies infringing on the First Amendment right of expressive association of a large, non-selective, quasi-commercial organization, so long as the infringement is no greater than necessary to achieve the state's purpose.

Facts:

• The United States Jaycees is a national nonprofit organization whose bylaws limited regular membership to men between the ages of 18 and 35.
• The organization's stated purpose is to provide young men opportunities for personal development, leadership training, and participation in civic affairs.
• Women and older men were permitted to be 'associate members' but could not vote, hold office, or participate in certain awards programs.
• The Jaycees was a large organization with approximately 295,000 members and was generally unselective in its admission criteria, apart from age and sex.
• In 1974 and 1975, the Minneapolis and St. Paul chapters began admitting women as full members in violation of the national bylaws.
• In response, the national Jaycees organization imposed sanctions on these chapters and threatened to revoke their charters.
• Members of the two Minnesota chapters filed charges with the Minnesota Department of Human Rights, alleging the national organization's policy constituted illegal sex discrimination under the state's Human Rights Act.
• The Minnesota Human Rights Act prohibits sex discrimination in a 'place of public accommodation,' which it defines broadly to include businesses offering goods, services, or privileges to the public.

Procedural Posture:

• Members of two local Minnesota chapters of the Jaycees filed charges of discrimination with the Minnesota Department of Human Rights against the national organization.
• A state administrative hearing examiner concluded the Jaycees was a 'place of public accommodation' under the Minnesota Human Rights Act and had engaged in an unfair discriminatory practice.
• The United States Jaycees filed suit in the U.S. District Court for the District of Minnesota, which certified the question of the Act's applicability to the Minnesota Supreme Court.
• The Minnesota Supreme Court, a state's highest court, held that the Jaycees organization was a 'place of public accommodation' within the meaning of the Act.
• The case returned to the U.S. District Court, which entered judgment in favor of the state officials, upholding the application of the Act.
• The United States Jaycees, as appellant, appealed to the U.S. Court of Appeals for the Eighth Circuit, an intermediate federal appellate court.
• The Court of Appeals reversed, holding that applying the Act to the Jaycees violated the members' First Amendment rights of association.
• Minnesota state officials, as appellants, petitioned the U.S. Supreme Court for review.