Find Court Cases > New York State Club Association. v. City of New York

New York State Club Association. v. City of New York

Case Date: 02/23/1988
Docket No: none

Facts of the Case 

The City of New York amended its Human Rights Law prohibiting discrimination in public places to include certain social clubs that were not "distinctly private." Particularly, the amendment applied anti-discrimination laws to social clubs and institutions that hosted dining regularly, retained more than four hundred members, and received funding from non-members in order to promote business interests. The amendment did not apply to religious, charitable, and education organizations because the city deemed that they were not centers of business activity. The New York State Club Association, a group of 125 clubs, contended in a state trial court that the new law violated its associational rights provided by the First and Fourteenth Amendments. The trial court ruled in favor of the city. A state appellate court and the New York Court of Appeals both affirmed, finding that the city's compelling interest in eliminating discrimination justified the restrictions on associational rights.

Question 

Did the City of New York violate First Amendment rights to free association when applying anti-discrimination laws to social clubs that were not "distinctly private"?

Argument New York State Club Assn. v. New York City - Oral ArgumentFull Transcript Text  Download MP3 Conclusion  Decision: 9 votes for New York City, 0 vote(s) against Legal provision: Article 3, Section 2, Paragraph 1: Case or Controversy Requirement

No. Justice Byron R. White delivered the opinion for a unanimous court. The Court examined the clubs subjected to anti-discrimination laws closely and found "no evidence of any club, let alone a substantial number of clubs, for whom the Law impairs the ability to associate or to advocate public or private viewpoints." In addition, many of the clubs showed characteristics of a public nature. Often strangers attended club functions, partook in meals, and made financial contributions. So long as the clubs were sufficiently open to this type of exposure to outsiders, the clubs could not be closed to certain types of people on account of their race, sex, or religion. Prohibiting this type of discrimination did not impair a club's ability to advance a viewpoint because clubs could still select people for membership based on whether they shared similar beliefs.