In the case of Board of Directors of Rotary International v. Rotary Club of Duarte, the U.S Supreme Court ruled in favor of a California-based chapter (Duarte) that had been expelled by Rotary International for admitting women as members. The court held that the state law used to challenge this expulsion did not violate the First Amendment rights to freedom of association claimed by Rotary International. The international organization argued their constitutional right would be infringed upon if they were forced to admit women because it would alter their fundamental character and message. However, Justice Lewis F Powell Jr., writing for a unanimous court, stated that admitting women wouldn't prevent them from accomplishing any legitimate purposes or change its basic nature since membership wasn’t based on particular viewpoints or ideologies but rather was open to all business and professional leaders who met certain criteria.

In the dissenting opinion for Board of Directors of Rotary International v. Rotary Club of Duarte, Justice Stevens argued that the majority's decision to force private clubs like the Rotary Club to admit women as members was a violation of their First Amendment rights. He contended that while gender discrimination is indeed reprehensible and should be combated in most contexts, it does not justify overriding an organization's right to freedom of association. According to him, compelling such organizations under state law to accept individuals they do not wish could lead down a slippery slope where any group with discriminatory membership policies - religious groups or political parties for example - could also be forced by law into accepting unwanted members. This would infrarily impinge on their constitutional rights.