Roberts v. United States Jaycees

468 U.S. 609 (1984)

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Nature of the Case

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Facts

The United States Jaycees (P), a national membership organization did not admit females to regular membership but only associate membership in which the females remitted lower dues and had limited leadership opportunities. In 1974 and 1975, respectively, the Minneapolis and St. Paul chapters of the Jaycees began admitting women as regular members. Currently, the memberships and boards of directors of both chapters include a substantial proportion of women. As a result, the two chapters have been in violation of the national organization's bylaws for about 10 years. The national organization imposed sanctions on the Minneapolis and St. Paul chapters for violating the bylaws, including denying their members eligibility for state or national office or awards programs, and refusing to count their membership in computing votes at national conventions. The national chapter threatened revocation of the branches' charters. The branch chapters asserted that the national chapter's membership policy concerning women was unlawful gender discrimination and pursued charges against the national chapter under the Minnesota Human Rights Act. P brought suit against Roberts (D), state officials to prevent enforcement of the Act. The District Court upheld the constitutionality of the Act. The District Court entered judgment in favor of D. The Court of Appeals determined that, because 'the advocacy of political and public causes, selected by the membership, is a not insubstantial part of what [the Jaycees] does,' the organization's right to select its members is protected by the freedom of association guaranteed by the First Amendment. It further decided that application of the Minnesota statute to the Jaycees' membership policies would produce a 'direct and substantial' interference with that freedom, because it would necessarily result in 'some change in the Jaycees' philosophical cast,' and would attach penal sanctions to those responsible for maintaining the policy. The court concluded that the State's interest in eradicating discrimination is not sufficiently compelling to outweigh this interference with the P’s constitutional rights, because the organization is not wholly 'public,' the state interest had been asserted selectively, and the antidiscrimination policy could be served in a number of ways less intrusive of First Amendment freedoms. The U.S. Supreme Court reversed in favor of D to open regular membership to women.