United States Jaycees v. Bloomfield

Summary

The District of Columbia Court of Appeals reviewed a preliminary injunction requiring the United States Jaycees and the District of Columbia Jaycees to refrain from sex discrimination in membership and from taking action against a local chapter that admitted women. The court held that the Jaycees was neither a "place of public accommodation" nor an "educational institution" under the District of Columbia Human Rights Act. It further concluded that the appellees were unlikely to succeed on their contract and promissory-estoppel theories because the pilot membership program was temporary and no continuing membership promise was shown. The court reversed and remanded the order granting the preliminary injunction.

Holdings

1. The appellees failed to show a substantial likelihood of success because the United States Jaycees was not a place of public accommodation as that term is defined by the Act.
2. The appellees failed to show a substantial likelihood of success because the Jaycees was not an educational institution within the plain meaning of the Act.
3. The appellees were unlikely to succeed on their contract claim because the Pilot Program was expressly temporary and experimental, and the Jaycees' membership later rejected a proposed bylaw change extending regular membership to women.
4. The appellees were unlikely to succeed on promissory estoppel because they presented no evidence that the Jaycees promised continuing membership beyond the Pilot Program.
5. The trial court erred in granting the preliminary injunction because the appellees had not shown a substantial likelihood of success on their statutory, contract, or promissory-estoppel claims.

Questions Presented

1. Whether the appellees showed a substantial likelihood of success on their claim that the United States Jaycees was a place of public accommodation under the District of Columbia Human Rights Act.
2. Whether the appellees showed a substantial likelihood of success on their claim that the United States Jaycees was an educational institution under the Act.
3. Whether the Pilot Program modified the Jaycees' bylaws or otherwise created a contractual obligation to continue the appellees' regular memberships.
4. Whether the appellees showed a substantial likelihood of success on a promissory-estoppel theory.
5. Whether the trial court properly issued the preliminary injunction.

Disposition

reversed_and_remanded