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
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.