The Christian Legal Society (CLS) at Southern Illinois University School of Law is a student chapter of the national Christian Legal Society, whose purposes include fellowship, promoting justice and religious liberty, Biblical conflict resolution, and discipling and nurturing Christian law students. In February 2005, a University official informed CLS that a student had filed a complaint with the University, claiming that CLS’s membership and leadership policies violated a university policy requiring student organizations to adhere to all appropriate federal or state nondiscrimination laws. In response to this complaint, the University revoked CLS’s registered status in March 2005. It claimed CLS’s policies violated the “Southern Illinois University-Carbondale [SIUC] Affirmative Action/Equal Employment Policy” as well as a Policy of the Southern Illinois University Board of Trustees that required all recognized student organizations to “adher[e] to all appropriate federal or state laws concerning nondiscrimination and equal opportunity.” The University proceeded to strip the chapter of all benefits associated with registered status. CLS filed a lawsuit against Southern Illinois University, claiming that its “nondiscrimination” policy violated the First Amendment.
WIN. On July 10, 2006, the U.S. Court of Appeals for the Seventh Circuit ruled that Southern Illinois University’s “nondiscrimination” policy violated CLS’s right to free association under the First Amendment. The Seventh Circuit ordered the district court to enter a preliminary injunction against Southern Illinois University’s policy.
This case was a watershed moment for student group free association. The U.S. Court of Appeals for the Seventh Circuit confirmed that Christian student organizations have a First Amendment right to associate freely based on their beliefs.

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