Roberts v. United States Jaycees
468 U.S. 609 (1984)

  • The Jaycees were a pro-business organization geared toward young men. Women and old men could only be associate members and couldn’t vote or hold office.
  • Two Minnesota chapters of the Jaycees bucked the system and began letting in women as full members. The national organization revoked the chapters’ licenses.
  • The chapters sued under a Minnesota law prohibiting discrimination (Minnesota Human Rights Act). The national organization countersued, claiming that the MHRA was unconstitutional.
    • The national organization claimed that they had a right of free association under the 1st Amendment, and Minnesota could not tell them who could or couldn’t join their club.
  • The Appellate Court found the MHRA to be unconstitutional.
    • The Appellate Court found that the MHRA was a violation of the 1st Amendment’s right to free association.
  • The US Supreme Court reversed.
    • The US Supreme Court applied a balancing test between the 1st Amendment right of free association and the compelling government interest in prohibiting discrimination, and found that the government interest outweighed the Jaycees’ free association rights.
    • The Court found that letting in women didn’t impose any serious burden on the male members’ rights.
  • Compare to Boy Scouts of America v. Dale (530 U.S. 640 (2000)), which said that the Boy Scouts could keep homosexuals out of their club.
    • The difference is that the Boy Scouts advocated against homosexuality, and so the Court felt they should be forced to accept someone who didn’t share their beliefs. But in this case, the Jaycees didn’t advocate against women businessmen, so having women members didn’t go against their fundamental principles.