Roberts v. United States Jaycees

The case established what was at the time the prevailing framework for analyzing claims of associative freedom, holding that the Minneapolis branch of the United States Jaycees could not bar women from becoming voting members.

[17] The Court concluded that the Minnesota Human Rights Act does not discriminate on the basis of viewpoint, either facially or as applied, meaning it does not relate to the suppression of ideas.

[18] The Court also found that the statute used the least restrictive means, as the Jaycees had failed to show that the Act burdens male members' freedom of association to a meaningful degree.

[19] The Majority said that the Jaycees, or future parties, have to make a "substantial" showing that the admission of unwelcome members would change the group's message.

"[24] Applying that framework to the facts, Justice O'Connor concluded that the Jaycees were a commercial association, as they call their members "customers", and refer to memberships as goods that they sell.

[27] Tommy Todd, President of the Jaycees, said the group was disappointed with the ruling but would comply, citing the Supreme Court's role in the American constitutional framework.

[28] Women's groups, who had challenged similar laws in states including New Jersey, New York and Connecticut, celebrated the authoritative quality of the Court's 7-0 ruling.

[29] Liberal scholars like Linda McClain have argued that those who praise the decision overestimate the effect that joining business groups like the Jaycees has on women's equality.