On November 3, 2009, the Supreme Court of Ireland held that the Portmarnock Golf Club could maintain its rule prohibiting female membership free from the sanctions of Ireland’s antidiscrimination laws. Portmarnock is representative of the numerous private golf clubs that continue to promote discrimination against women. Despite significant advances in gender equality, private country clubs in the United States, the United Kingdom, and Ireland remain bastions of codified gender discrimination. Many of the most prominent golf clubs hold firmly to discriminatory policies established generations ago. Opposition to these policies has come in various forms of protest and litigation, with mixed results. The private clubs have frequently asserted the right to free and exclusive association to defend their actions. Moreover, some of golf’s most famous private clubs continue to practice egregious forms of discrimination against women largely free from legal challenges. This Note examines the existing legal status of gender discrimination at private country clubs in the United States, the United Kingdom, and Ireland and offers a three-prong approach to litigation against clubs engaging in disparate treatment of women.
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