Thursday, November 14, 2013

Roberts v. United States Jaycees case brief

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

Petitioner human rights commissioner (commissioner) appealed from a decision of the United States Court of Appeals for the Eighth Circuit that concluded that requiring respondent organization to admit women as full voting members pursuant to the Minnesota Human Rights Act (act), specifically Minn. Stat. § 363.03(3) (1982), violated the First and Fourteenth Amendment rights of the organization's members.

The organization had threatened to revoke the charters of two of its chapters because they were admitting women as regular members in violation of the organization's bylaws. The organization argued that requiring it to admit women as regular members violated its members' associational rights.


  • The Court reversed. In doing so, the Court held that:
  • (1) the act was not unconstitutionally vague nor overbroad; 
  • (2) several features of the organization clearly placed it outside of the category of relationships worthy of constitutional protection because it was a large and basically unselective group; 
  • (3) apart from age and sex, neither the national organization nor the local chapters used any criteria for judging applicants for membership; 
  • (4) the organization lacked the distinctive characteristics that might afford constitutional protection to the decision of its members to exclude women; and 
  • (5) the state's compelling interest in eradicating discrimination against its female citizens justified the impact that application of the act may have on the male members' associational freedoms.
The judgment was reversed.

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