A pretty obvious conclusion, since the nightclubs aren’t the government, and the Equal Protection Clause applies only to the government. But now there’s a Second Circuit decision so holding. Thanks to How Appealing for the pointer.
A pretty obvious conclusion, since the nightclubs aren’t the government, and the Equal Protection Clause applies only to the government. But now there’s a Second Circuit decision so holding. Thanks to How Appealing for the pointer.
Orin Kerr says:
In my view, any practice celebrated by Kool & the Gang carries a strong presumption of constitutionality.
[UPDATE: Oh, rats, Howard beat me to the joke.]
September 1, 2010, 12:21 pmtroll_dc2 says:
From the way the case seems to be formatted, it may not be designated for official publication. But the lower court decision is published, and the appeals took took over a year to issue its ruling. Moreover, it can be said to have settled an issue in such a way that no one else will want to replough the same ground. So it really ought to be published in F.3d.
ADD: On second thought, maybe I reacted too quickly. The fact that the court provided a summary probably means that is going to be published. I guess I reacted to how the opinion looked.
September 1, 2010, 12:29 pmKen Arromdee says:
If a nightclub were to get a man arrested for trespassing by being present on a ladies’ night without paying, wouldn’t that be action by the government?
September 1, 2010, 12:30 pmSmooth, like a Rhapsody says:
Ken:
September 1, 2010, 12:32 pmI think that a club owner can eject a patron and give a trespass warning to anyone.
Sasha Volokh says:
“It is with great reluctance that we call attention to a case upholding the constitutionality of discrimination against African Americans, but until the Supreme Court revisits Moose Lodge, we are required to follow its holding.”
What’s up with that???
September 1, 2010, 12:33 pmSmooth, like a Rhapsody says:
September 1, 2010, 12:42 pmTransplanted Lawyer says:
The more interesting question is whether Ladies’ Nights violate Title VII or other anti-discrimination laws applicable to public accommodations.
September 1, 2010, 12:42 pmShelbyC says:
Agreed, but there’s a SCOTUS case (Bell v MD, IIRC) that almost ruled the other way. And many folks used that argument on the threads on racial discrimination in public accomodations a few months ago.
September 1, 2010, 12:52 pmAF says:
What’s up with the case or what’s up with the Second Circuit’s reluctance to rely on it?
September 1, 2010, 12:54 pmruuffles says:
What does this reference mean?
September 1, 2010, 12:59 pmArthur Kirkland says:
It may not be unconstitution, but it could constitute a violation of liquor licensure terms in many states.
September 1, 2010, 12:59 pmruuffles says:
From the opinion
Is this the case here, that the private club is not open to the public?
September 1, 2010, 1:02 pmDavid M. Nieporent says:
The latter; Orin’s reaction was the same as mine. That seemed utterly gratuitous. There’s a Supreme Court case directly on point, the case is four decades old (that is, old enough to be well-established, but not so old that it was decided in another era in which values or theories were entirely different), and the court apologizes for citing it and implicitly lobbies for it to be overturned? And does so in a frivolous lawsuit filed by a nutjob over a trivial issue?
September 1, 2010, 1:02 pmShelbyC says:
I’m not sure it matters. They relied on Moose lodge for the holding that a liquor license isn’t state action for 14A purposes.
September 1, 2010, 1:04 pmruuffles says:
Oh cmon now, conservative judges play this game all the time with respect to Roe and religious freedom cases. Moreover, how is this frivolous? Would you say it were frivolous if it were a public club?
September 1, 2010, 1:04 pmMatthew in Austin says:
Am I to understand that it is constitutional for a night club to have a “Whites Only” policy or “Blacks pay $1 more” policy, because they are private institutions and not government?
I know discrimination practices are illegal in hiring/firing/salary decisions, but is that only because of specific acts of Congress? (ie Civil Rights Act)
So, beyond the specific employment related cases outlined in that legislation, companies are allowed to implement outright discriminatory practices toward their customers? I kind of assumed practices like that were illegal. My own ignorance, I guess.
September 1, 2010, 1:04 pmruuffles says:
This was my question as well. It appears that it’s not only a private institution but also private in the sense that it has closed membership and not open to the public. It’s interesting that it’s not so private as to not require a liquor license (compare to say a house party).
September 1, 2010, 1:07 pmRealistLiberal says:
There is a difference between “illegal” and “unconstitutional.” Would it be constitutional to have a Whites Only Night? Yes. Would it be illegal? Very likely so.
On a totally separate note, when will these brain dead guys realize that Ladies Nights are not to benefit Ladies? They are to benefit guys by having more women at a particular bar and increase the chances of each guy in there. I vaguely remember Ilya posting something along those lines some time ago.
September 1, 2010, 1:14 pmSigivald says:
Matthew: Yes, that’s the Civil Rights Act.
It also controls discrimination in “public accommodations” (42 USC 2000 (a) and following).
The CRA covers “places of entertainment” as PAs, but does not include gender as a protected category, only “race, color, religion, or national origin”.
So yes, it’s legal to discriminate on gender pretty much anywhere, privately, until Congress changes that.
(Which it won’t, because there’s too much popular support for things like women-only gyms and the like. There doesn’t seem to be a problem with sex-based discrimination in public accommodations such that any great harm is being done to anyone.
Thus no grounds for Congress to stir anything up to “fix” it; not only would it not get them any votes, it might well cost them some.
A perfect formula for inaction.)
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September 1, 2010, 1:17 pmShelbyC says:
The fourteenth amendment says, “No State shall … deny to any person within its jurisdiction the equal protection of the laws.” It doesn’t say anything about private discrimination. Many forms of private discrimination are illegal, but that issue doesn’t seem to be raised here.
September 1, 2010, 1:22 pmRowerinVA says:
Responding to:
Ken, yes, that’s action by the government but it’s not unconsitutional discrimination by the government. And yes, there’s a difference, which becomes obvious once you flip Matthew’s comment:
“Constitutional” is the wrong word to describe actions by private persons. The Constitution restrains the government, not private persons, and in fact the Constitution states that all rights are the people’s unless specifically granted to the government.
But to answer Ken’s question, the government must be able to defend the core rights of individuals to choose which whom they will associate for private, religious, and political advocacy reasons, by trespass arrests (for example) if necessary. So long as the government does that it a viewpoint-neutral way, the government should not be charged with itself expressing those private, religious, and political advocacy views.
September 1, 2010, 1:22 pmAF says:
I think you mean Sasha’s reaction.
As for whether Moose Lodge’s holding that it is constitutional for a state to grant a license to a racially discriminatory organization is well-established, I think that’s questionable. More accurately, it has been rendered largely moot by anti-discrimination statutes. It’s fair to say that values with respect to racial segregation were pretty different in 1972 — support for segregation was rapidly waning, of course, but far from the taboo it is today.
In any event, it’s hard to see what’s wrong with the court expressing its distaste for the case in the course of following it.
September 1, 2010, 1:23 pmpete the elder says:
Considering the constitution is silent about private entities practicing discimination then yes it is constitutional. I think that would be pretty obvious since whites only policies were legal and upheld by the supreme court for decades until congress passed a bunch of laws to change that. The constition is silent about a lot of policies.
September 1, 2010, 1:25 pmArthur Kirkland says:
In general, a liquor license is required when access to alcohol depends on payment (direct or indirect). I believe that fewer than half the entities that need liquor licenses in the United States possess licenses. In many cases — users favored by government or society — it often becomes a legal problem only if and when one of the speakeasy customers causes harm and the bootleggers get sued.
September 1, 2010, 1:28 pmShelbyC says:
It’s hard to imagine an argument that it would be unconsititutional, though. The same logic would make it unconstitutional for the government to issue a marriage license to somebody that had a preference in his choice of spouse.
September 1, 2010, 1:30 pmCassandra says:
Austin, a more enlightened city than NYC, provides:
§ 5-2-4 PROHIBITED PRACTICES.
(A) A person is entitled to the full and equal enjoyment of the goods, services, facilities, privileges, advantages, and accommodations of a public accommodation, without discrimination or segregation based on race, color, religion, sex, sexual orientation, gender identity, national origin, age, or disability.
(B) A person, including the owner, operator, or lessee of a public accommodation may not directly or indirectly exclude, segregate, limit, refuse or deny a person the accommodations, advantages, facilities, benefits, privileges, services, or goods of the public accommodation based on race, color, religion, sex, sexual orientation, gender identification, national origin, age, or disability.
(C) A person, including the owner, operator, or lessee of a public accommodation, may not circulate, issue, display, post, mail, or publish a statement, advertisement, or sign that indicates that the accommodations, advantages, facilities, benefits, privileges, services, or goods of the public accommodation will be denied to an individual based on race, color, religion, sex, sexual orientation, gender identification, national origin, age, or disability, or that the patronage or presence of an individual is objectionable, unwelcome, unacceptable, undesirable, or unsolicited based on race, color, religion, sex, sexual orientation, gender identification, national origin, age or disability.
and in any case, RealistLiberal’s comment,
“On a totally separate note, when will these brain dead guys realize that Ladies Nights are not to benefit Ladies? They are to benefit guys by having more women at a particular bar and increase the chances of each guy in there. I vaguely remember Ilya posting something along those lines some time ago”
is silly, since gay men may have no interest in a bar polluted with ladies. Nor do some married men or even normal single guys like me who prefer to meet women elsewhere. Furthermore, shouldn’t the NYC club’s promotion be limited to “ladies” so as not to include married tramps?
September 1, 2010, 1:34 pmMatthew in Austin says:
Thanks everyone. So the issue of private business discrimination is just legal vs illegal based on passed legislation, not constitutional versus unconstitutional. Laws have been passed preventing discrimination in public accomodations, including places of entertainment, but those laws do not include gender discrimination, and that is likely to remain the status quo.
September 1, 2010, 1:36 pmruuffles says:
I’m going to make a Yglesias-esque statement and say that liquor licenses serve no purpose other than as a barrier to entry.
September 1, 2010, 1:38 pmOrin Kerr says:
Yes, it was Sasha’s reaction, not mine.
At the same time, I don’t think I follow ruuffles’s reaction that “Oh cmon now, conservative judges play this game all the time with respect to Roe and religious freedom cases.” I don’t think I recall seeing a majority opinion by a lower court judge in which a court said that it was “with great reluctance” that the court was invoking Supreme Court precedent — especially because of the facts of that case rather than its legal holding.
September 1, 2010, 1:41 pmSmooth, like a Rhapsody says:
Yglesias-esque …
“Yglesiastic”?…
September 1, 2010, 1:42 pmruuffles says:
Apologies. I was thinking of some concurrences by individual judges.
September 1, 2010, 1:42 pmShelbyC says:
Well, I guess the Thomas [Edit]dissent in Lawrence is similar.
September 1, 2010, 1:44 pmAJK says:
Yes, it is clearly constitutional. Laws could be passed making it illegal (those laws would also be constitutional). Laws could, presumably, also be passed making ladies nights illegal. But, it would seem, the lawsuit here only raised constitutional issues, rather than statutory violations.
September 1, 2010, 1:47 pmDon Miller says:
I would agree with this. Bar owners in most regions of the country fight to keep the number of liquor licenses low. Limiting licenses results in two things, 1. more patrons for the few bars that are available, 2. artificially making existing liquor licenses more valuable when the owner dies or decides to sell it.
There have been liquor license owners that have sued (and lost) when States started issuing more licenses. The last case I heard about they argued it was a regulatory taking because now their licenses were less valuable.
September 1, 2010, 1:49 pmDavid M. Nieporent says:
Like you can tell them apart.
That wasn’t the legal question presented. The plaintiff didn’t sue the state for granting the club a liquor license; it sued the club for discriminating.
I’m curious what relevant anti-discrimination laws do you think had yet to be passed by 1972. (Wallace didn’t exactly get elected, btw, and that was 1968, not 1972.). The Moose Lodge case – as this holding shows – is in no way moot.
Well, it’s better than NOT following it – but as I said, it was gratuitous.
September 1, 2010, 1:49 pmDavid M. Nieporent says:
Almost, but not quite. Federal law may not include gender — but many if not most states have anti-discrimination laws that do include gender. As do many municipalities. (Including New York, which includes pretty much every category under the sun as a protected class.)
September 1, 2010, 1:56 pmSasha Volokh says:
I should also clarify: There also seems to be no indication that Moose Lodge is out of line with the rest of state action law. It’s one thing to cite Korematsu with some reluctance, because it’s a case that’s never been overruled but is of doubtful validity today. A lower court would have to follow it, but only because it has to, and it may well get reversed on appeal. But Moose Lodge is not only “good law” in the sense of being a case on point, it’s also a case of continuing validity because it fits in perfectly with all the rest of state action law.
September 1, 2010, 1:56 pmKen Arromdee says:
Yet whenever the subject gets brought up for racial discrimination, one of the replies I see is always “you may claim that it’s private action, but if a black gets arrested for trespassing in your whites-only restaurant, that’s state action.
September 1, 2010, 2:02 pmDavid M. Nieporent says:
It’s frivolous because
September 1, 2010, 2:04 pm(a) that it isn’t state action is well-established;
(b) the plaintiff somehow ‘forgot’ to sue under long-existing anti-discrimination statutes which might actually be relevant;
(c) ladies’ nights are not discrimination against men;
(d) the plaintiff included in his pleadings nutty claims like “Without action on our part, Den Hollander paints a picture of a bleak future, where ‘none other than what’s left of the Wall Street Moguls’ will be able to afford to attend Nightclubs.”
(e) Roy Den Hollander is a known fruitcake, who routinely files frivolous lawsuits against what he perceives to be feminism.
ShelbyC says:
Hey, I’ve never heard a court following Miranda say, “It is with great reluctance that we call attention to a case that allowed a rapist to go free…”
September 1, 2010, 2:05 pmCalderon says:
Sasha Volokh said:
I’m not sure sure a lower court would be bound to follow Korematsu. In Adarand an S Ct majority stated that “Korematsu demonstrates vividly that even ‘the most rigid scrutiny’ can sometimes fail to detect an illegitimate racial classification.” (emphasis added). That language seems to be an official S Ct acknowledgement that Korematsu was wrong. I also thought that was another affirmative action case where the S Ct majority referred to Korematsu as an “error,” but maybe I’m misremembering.
September 1, 2010, 2:14 pmPhil says:
As Justice Scalia would probably say about this case(and so many others)-
September 1, 2010, 2:17 pmGarbage in, garbage out.
Sasha Volokh says:
RowerinVA, Ken Arromdee: Shelley v. Kraemer does imply that, when you use neutral law (like trespass law) to discriminate on the basis of race, the government is engaged in discriminatory state action when it enforces that law. Shelley v. Kraemer is probably incorrect, and it has never been followed outside of the narrow context of racially discriminatory covenants, but it’s still “good law” and has never been reversed.
September 1, 2010, 2:45 pmJeff Hall says:
Ah, so if lawyers ran the bar industry Ladies Nights would be called Meat Market nights? Would customers have to pay per drink or by the billable hour?
September 1, 2010, 2:55 pmShelbyC says:
In Bell v MD some folks wanted to apply it more broadly, but the outcome got kind of funny.
September 1, 2010, 3:04 pmDavid Schwartz says:
Shelley v. Kraemer is distinguishable for two reasons:
In Shelley v. Kraemer, to enforce the law, the State would have to make an official finding that Shelley was a person “of the Negro or Mongolian Race” and therefore prohibited by the covenant from taking possession of the property. That is, the State would have to itself determine Shelley’s race and act on that basis. In this case, the State need not determine anyone’s race and in no way is hinging its own actions on the basis of such an official determination.
Also, in Shelley v. Kraemer, the State was asked to deprive Shelley of a property right of ownership and occupancy. In this case, the State is not being asked to deprive anyone of any right.
Shelley v. Kraemer is more akin to inheritance cases where the Court had to determine if someone “married a member of the Jewish faith”. And this case is more like a case where that determination was made by an outside party and the State is being asked to enforce that determination.
September 1, 2010, 3:18 pmCJColucci says:
Furthermore, shouldn’t the NYC club’s promotion be limited to “ladies” so as not to include married tramps?
What makes you think we guys are looking for “ladies” at Ladies’ Night? And “married tramps” are often the best kind, for a variety of reasons.
September 1, 2010, 3:42 pmSasha Volokh says:
David Schwartz: I’m not sure I buy your effort to distinguish Shelley.
Determining whether someone is Jewish seems to implicate the Establishment Clause — these religious determinations are objectionable for a different reason than racial determinations. For Equal Protection purposes, if we buy that at least some affirmative action is permissible, surely it’s permissible for the state to determine whether someone is black.
As for depriving someone of an ownership right, it’s true that Shelley had to do with a property transfer while a trespass rule just has to do with licenses to be on property (and not property rights in the strict sense). But what difference should that distinction make? In Shelley the question was whether to neutrally enforce a contract between landowners — the restrictive covenant at issue. Sure it’s racist on its face, but contract law can neutrally enforce a racist contract. Similarly with neutral enforcement of trespass law even if the landowner tells the policeman to boot off everyone who’s black.
It’s true that in the usual trespass case you just tell the cop to eject a particular person, so the government doesn’t itself have to consciously do something racist, as it did in Shelley where it was in the terms of the contract that was asked to be enforced. That seems like a good distinction, though I don’t think it makes Shelley rightly decided. But it seems like it would apply in the hypo above where you tell the policeman “I object to black people on my property and here are a bunch of them staging a sit-in — eject whatever black people you find.”
September 1, 2010, 3:51 pmxx says:
Some conservatives think that some liberal judges reach particular rulings only because such rulings are more acceptable in the judges’ social circle.
September 1, 2010, 4:01 pmxx says:
Most Circuits have fairly strict rules stating that they may not find that supreme court precendent or prior panel precedent has been overturned by implication. So, at least on the precise issue on question in Korematsu, I think most circuits would be obligated to follow its holding.
September 1, 2010, 4:09 pmNickM says:
Area Man disagrees.
Nick
September 1, 2010, 5:09 pmDavid Schwartz says:
I’m not arguing that Shelley was rightly or wrongly decided. I’m just saying there’s a huge difference between telling a cop “issue that person a trespass notice” and telling a cop “issue a trespass notice to any black person you find”. In practice, I would expect a cop to honor the former and refuse the latter.
I also think there’s a huge legal difference, akin to the difference between, in an inheritance case, asking a court to determine if someone “married a Jew” and asking a court to honor such a decision made by a religious court.
Shelley was the latter, this is the former. (And again, I’m not arguing that this makes Shelly right or wrong or this right or wrong, just that it’s an important distinction between the two cases.)
As for the permissibility of the State determining if someone is black, I don’t think you can divorce the determination from its purpose. The tests one would use to determine whether someone is black or not are based on why you’re determining that — there is no one standard that makes sense in all cases. Is a toy car a car?
I don’t think the State can determine if someone is black for the purpose of taking away their property rights any more than the State can decide if someone “married a member of the White race” for purposes of inheritance. But I see no Constitutional reason the State can’t enforce a private determination — even in light of Shelley.
September 1, 2010, 5:20 pmJoseph Slater says:
Yeah, and the need to fit in at liberal “cocktail parties” is a repeated part of this meme. To which I say, can’t conservatives throw decent cocktail parties? Why do they always want to come to liberal ones?
September 1, 2010, 6:25 pmNickM says:
We’d rather barbecue and drink beer.
Nick
September 1, 2010, 6:46 pmCalderon says:
That’s completely true for when the reasoning of two decisions conflict, but I’d think it’d be a different issue if a Supreme Court case said that an earlier case were in “error” or described it as upholding an “illegitimate” distinction, even if the later opinion did not expressly say that it was overruling the earlier case.
September 1, 2010, 6:59 pmJ. Aldridge says:
meh, lawyers will drop the Equal Protection argument and say ladies nights violate the commerce clause (gender discrimination in a public establishment or something).
Never under estimate how badly flawed the American judicial system is.
September 1, 2010, 7:06 pmwhit says:
on this point, i just got a recreation guide from a local city and they said they were in compliance with ESSB 5967 that “prohibits discrimination against any person in a community athletics program on the basis of sex”
and in the same guide, they advertise a “Women’s Self Defense Workshop”
the description does not specifically say the workshop is LIMITED to women, just clearly targeted to them. but it doesn’t say men are allowed either. I am waiting to here from somebody connected with the park and rec dept. as to whether men can attend the self defense workshop or are excluded.
September 1, 2010, 7:39 pmArthur Kirkland says:
Do you grind your teeth every time you see a license plate . . . or a driver’s license?
September 1, 2010, 9:33 pmVinny B. says:
Anyone that is against ladies’ nights at bars, and especially upset enough about it to sue, obviously either cannot get a date or has not once enjoyed the fruits of ladies’ nights and the benefits many of us men have enjoyed thanks to cheaper booze for the broads.
I was a nightclub DJ many years, and ladies’ nights were a great way to pack the joint in the middle of the week. May they live on forever.
September 2, 2010, 1:10 amReaderY says:
It should be noted that foster parents, like a private prison or a government school and unlike private night clubs, to some degree are the government because they are the government’s agents to accept custody of a child the government has taken away from its parents.
I continue to be astonished that the constitution is regarded as prohibiting government from accommodating same-gender preference in some contexts, yet is regarded as requiring government to accommodate it in others which don’t seem to have much rational functional difference. If the governemnt interest in not promoting same-gender facilities and organization is compelling, how can it be irrational in differently-named ones that serve the same functional purpose? If irrational, how can it be compelling?
I do not understand how people who are morally opposed to same gender organizations and preferences and have no problem imposing their morals on others can get on their high horses and claim to find constitutional objections to people who are morally opposed to same-gender preference in slightly different kinds relationships.
Morality is an emotional thing to some degree. Everyone thinks their version of morality is the only possible rational one and any different conception is irrational. These types of arbitrary-seeming distinctions (from an outsider’s point of view) are quite common in human societies and a legislature is entitled to enact them. Societies need some sort of morality to guide them and there is no easy way to address differences in moral conceptions. We stumble and argue and hopefully gain experience as we go on and we do the best we can. Justices are supposed to have the discipline to take the outsider’s point of view in these things. They are not supposed to base “rationality” on their own subjective feelings about what is rational. Once they begin doing that, there’s no point in having legislatures. Justices may feel they know it when they see it. But so does everyone else, and a different way of knowing is not necessarily worse. Justice’s epiphanies on these matters may seem clear to them, but the clarity of their perceptions does not make these perceptions any more actually reliable than anyone elses. Feeling certain is not the same thing as knowing.
September 2, 2010, 4:34 amJoseph Slater says:
Well, I know some conservatives who prefer upscale cocktails. But if what you say is true, then conservatives wouldn’t be going to / wouldn’t care about liberal cocktail parties. And that is counter to the meme that conservative judges get all liberal because of their desire to go to liberal cocktail parties.
September 2, 2010, 9:27 amThursday Highlights | Pseudo-Polymath says:
[...] Why is this even a question? [...]
September 2, 2010, 10:44 amMichael Ejercito says:
Courts have generally recognized that only the Supreme Court may revisit its precedents and either overrule them, limit or broaden their scope, or reaffirm them in full.
From De Quijas v. Shearson, 490 U.S. 477,
From State Oil co. v. Khan, 522 U. S. 3
From Lawrence v. Texas, 539 U.S. 558
And from Chief Judge Alex Kozinski’s dissent in Silveira v. Lockyer, 312 F.3d 1052 (since vindicated by McDonald v. Chicago)
September 2, 2010, 11:57 amDavid Chesler says:
Not unconstitutional != legal. Got it.
Disagree that I shouldn’t object to ladies’ nights because I’m a man. The closest to being harmed by one was when my wife and I were out together and considered going into a club but found the cover was higher for me than for her. (In that case we were in the same position as if the club had split the difference. Other times I’m out in a group that is not evenly divided by gender, and we don’t care how many women are in the place. [For what it's worth, my undergraduate dorm had more straight women than straight men, in a time when the college as a whole was about 55:45 men to women, and it didn't do me any good.])
But do I need to be harmed particularly to dislike a policy? I wouldn’t be happy with a “Whites Only” club, or any club that practiced any form of “All the animals are equal, but some are more equal than others.”
September 2, 2010, 7:40 pmRicardo says:
I hear the National Review isn’t going to fill up its $2,000+ per person Caribbean cruise — all those conservatives would much rather be hunting and fishing :-)
September 3, 2010, 7:51 amNeeq says:
Can you say “Moose Lodge”? Obviously a fail. Since we just finished State Action in Con. Law I was excited to make this immediate connection, i.e. liquor license is insufficient to establish state action.
September 4, 2010, 4:55 pm