Roberts v. United States Jaycees

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

Synopsis of Rule of Law. Government may infringe upon the right to associate when the regulation serves a compelling state interest that is unrelated to the suppression of ideas and cannot be achieved through any less restrictive means.

Facts. The United States Jaycees’ (Respondent) objective is to promote the growth of civic organizations for young men. Members are men between the ages of 18 and 35. Associate membership is available to older men and women. However, associates cannot vote, hold office, or participate in leadership training.
In 1974, the Minneapolis chapter began admitting women as regular members. But the national group refused to acknowledge their membership. Then in 1978, the national group threatened to revoke the local chapter’s membership because of the overt violation of the organization by-laws. The Minnesota chapter argues that the by-laws violate the Minnesota Human Rights Act that prohibits discrimination.

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

Held. 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.

Discussion. An association is protected if it involves items related to family such as marriage, education of children, or general personal liberty. These groups tend to be small and highly selective in decision-making. But large business like organizations do not embody the constitutional protection of personal liberty interests. Some of the relevant factors to use in determining whether an association will be immune from some regulation are the size, purpose, policies, selectivity, and congeniality of the group.