Roberts v. United States Jaycees Case Brief

Why is the case important?

Local Jaycees were threatened with expulsion from the national group because they allowed women to hold full-time membership.

Facts of the case

According to its bylaws, membership in the United States Jaycees was limited to males between the ages of eighteen and thirty-five. Females and older males were limited to associate membership in which they were prevented from voting or holding local or national office. Two chapters of the Jaycees in Minnesota, contrary to the bylaws, admitted women as full members. When the national organization revoked the chapters’ licenses, they filed a discrimination claim under a Minnesota anti-discrimination law. The national organization brought a lawsuit against Kathryn Roberts of the Minnesota Department of Human Rights, who was responsible for the enforcement of the anti-discrimination law.

Question

Does the state statute violate the freedom of association rights of Respondent?

Answer

No. Respondent is a large organization that is not selective of its participants and does not have the characteristics worthy of constitutional protection. The statute interferes with the organizations infrastructure but is justified by the compelling state interest in eliminating discrimination. Respondent already allows women as associate members, so this does not represent an overly burdensome change.

Conclusion

Several features of respondent organization clearly placed it outside of the category of relationships worthy of constitutional protection because it was a large and basically unselective group. Apart from age and sex, neither respondent nor its local chapters used any criteria for judging applicants for membership. Respondent lacked the distinctive characteristics that might afford constitutional protection to the decision of its members to exclude women. 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.

  • Case Brief: 1984
  • Appellant: Roberts
  • Appellee: United States Jaycees
  • Decided by: Burger Court

Citation: 468 US 609 (1984)
Argued: Apr 18, 1984
Decided: Jul 3, 1984