Curran v. Mount Diablo Council of the Boy Scouts of America

In both the Curran and Randall cases, four justices of the California Supreme Court offered separate, concurring opinions, each of which pointed out the need to further clarify what constitutes a business establishment under the Unruh Civil Rights Act. The ruling in the two California cases will affect the court's decision in a similar case involving a teenager, Katrina Yeaw, of Rocklin, California. She contends that the Boy Scouts discriminated against her when it denied her admission based on gender.

The BSA is appealing the New Jersey case to the state's supreme court. If it loses, it will appeal the decision to the U.S. Supreme Court. A dozen other suits involving similar issues are making their way through the courts. If the New Jersey case reaches the Supreme Court, much of the confusion surrounding the BSA's right to exclude certain individuals from the organization will undoubtedly be cleared up.