Roberts v. United States Jaycees
Roberts v. United States Jaycees is a significant Supreme Court case that addresses the intersection of sex discrimination and the right to free association under the First and Fourteenth Amendments. The case arose when the Minnesota Human Rights Act, which prohibits sex discrimination in public accommodations, was applied to the Jaycees, a private service organization that exclusively allowed male members. The Jaycees challenged this enforcement, arguing that being required to admit women violated their constitutional rights.
In a unanimous decision, the Supreme Court ruled against the Jaycees, emphasizing that the organization was not a small or selective group, and that admitting women would not fundamentally alter its purpose or beliefs. The Court recognized that while freedom of association is protected, it can be limited in the interest of eradicating discrimination. This ruling set a precedent, establishing that public accommodation laws could apply to various private organizations, ensuring broader access and inclusivity.
However, later rulings, such as in Hurley v. Irish-American Gay, Lesbian, and Bisexual Group of Boston, demonstrated that the right to free association could still protect some private groups from being compelled to include certain members. This case remains a touchstone for discussions about discrimination, membership rights, and the balance between private organization freedoms and public policy goals.
Roberts v. United States Jaycees
Date: July 3, 1984
Citation: 468 U.S. 609
Issues: Sex discrimination; freedom of association
Significance:Jaycees was a landmark Supreme Court decision that held that the state’s interest in combating sex discrimination was sufficiently compelling to justify application of an antidiscrimination statute to some private organizations.
The Minnesota Human Rights Act prohibited sex discrimination in a place of public accommodation. The state’s enforcement agency applied the statute to the Jaycees, a private service club that restricted membership to men. The Jaycees brought a lawsuit, claiming that requiring the organization to accept women as members violated its right of free association guaranteed by the First and Fourteenth Amendments.
By a 7-0 vote, the Supreme Court rejected the claim. Writing for a majority, Justice William J. Brennan, Jr., recognized constitutional protection for two varieties of freedom of association: the right to choose “intimate human relationships” and the right to engage in expressive activities. Brennan noted that the Jaycees was “neither small nor selective,” and that the presence of women in the organization would require no change in its announced creed. Such a small limit on the free association rights of the Jaycees was justified by the state’s interest in eradicating discrimination. In a more narrow concurrence, Justice Sandra Day O’Connor argued that the Jaycees operated more like a commercial organization than a private club.
Subsequent to the Jaycees decision, the Court ruled that public accommodation laws apply to many other private organizations. In New York State Club Association v. City of New York (1988), for instance, the Court held that certain all-male social clubs must admit women. However, in the case of Hurley v. Irish-American Gay, Lesbian, and Bisexual Group of Boston (1995), the Court held that the principle of free association permitted a private group to exclude a gay rights group from participating in its annual St. Patrick’s Day parade.