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

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.