## Facts

- A public law school operated a Registered Student Organization (RSO) program that granted recognized groups access to benefits such as student-fee funding eligibility, facilities, and official communication channels.
- To obtain and keep RSO status, student organizations had to comply with a nondiscrimination policy that the school applied as an “all-comers” rule: any student had to be allowed to participate, seek membership, and run for leadership positions, regardless of status or beliefs.
- A student religious organization required members and officers to sign a statement of faith and conform their conduct accordingly, including a rule limiting sexual activity to marriage between a man and a woman.
- The organization interpreted its criteria to exclude students who engaged in “unrepentant homosexual conduct” and students who did not share its religious beliefs.
- The school denied the organization RSO recognition because its membership and leadership requirements conflicted with the school’s all-comers condition.
- The organization sued under 42 U.S.C. § 1983, claiming violations of free speech, expressive association, and free exercise rights; the district court and court of appeals ruled for the school.

## Issues

1. Whether conditioning official recognition and related benefits for student organizations on compliance with an all-comers membership and leadership policy violates the First Amendment rights of a religious student group.
2. Whether the all-comers condition in a public law school’s RSO program is a reasonable, viewpoint-neutral restriction in a limited public forum.

## Decision

- The Supreme Court affirmed judgment for the school in a 5–4 decision.
- The Court treated the RSO program as a limited public forum and applied the standard permitting reasonable, viewpoint-neutral access rules.
- The Court held the all-comers policy was reasonable in light of the forum’s purposes, including equal access to student opportunities and avoiding exclusion based on beliefs.
- The Court held the policy was viewpoint neutral because it applied across the board to all student groups and turned on willingness to open membership and leadership eligibility, not on the group’s message.
- The Court rejected the expressive-association claim because the school did not force the group to accept unwanted members; it declined to provide recognition and subsidies unless the group complied with the access condition, while leaving the group free to exist and meet without RSO status.
- The Court rejected the free-exercise claim on the ground that the all-comers rule, as applied in the program, was neutral and generally applicable rather than targeted at religion.

## Legal Principles

- A public university’s recognized-student-organization program may be treated as a limited public forum, permitting restrictions that are reasonable in light of the forum’s purposes and viewpoint neutral.
- A uniformly applied “all-comers” rule requiring recognized student organizations to admit any student to membership and leadership eligibility can be a reasonable, viewpoint-neutral condition on access to official recognition and related benefits.
- Denial of recognition and subsidies for failure to comply with forum conditions is distinct from prohibiting speech or association; optional government benefits may be conditioned on compliance with neutral access rules.
- An all-comers condition that does not depend on a group’s ideology or religious views, but on openness to all students, does not constitute viewpoint discrimination on its face as applied uniformly.

## Conclusion

The Court upheld a public law school’s decision to deny official recognition to a religious student group that limited membership and leadership to those sharing its faith commitments, holding that a uniformly applied all-comers policy is a reasonable, viewpoint-neutral access rule in a limited public forum and does not violate the group’s First Amendment rights.


Christian Legal Soc’y Chapter of Univ. of Cal., Hastings Coll. of the L. v. Martinez, 561 U.S. 661 (2010)