In Roberts v. United States Jaycees, 468 U.S. 609 (1984), the Supreme Court described two "distinct senses" of constitutionally protected freedom of association. Id. at 617. In one line of decisions, the Court has recognized that certain kinds of personal bonds have played a critical role in the culture and traditions of the Nation by cultivating and transmitting shared ideals and beliefs; they thereby foster diversity and act as critical buffers between the individual and the power of the State. Roberts, 468 U.S. at 618-19. The Constitution protects these affiliations for intrinsic reasons, "as a fundamental element of personal liberty." Roberts, 468 U.S. at 618. These protected personal affiliations include marriage. See Roberts, 468 U.S. at 619. In a second line of decisions, "the Court has recognized a right to associate for the purpose of engaging in those activities protected by the First Amendment," because "an individual's freedom to speak, to worship, and to petition the government for the redress of grievances could not be vigorously protected from interference by the State unless a correlative freedom to engage in group effort toward those ends were not also guaranteed." Roberts, 468 U.S. at 618, 622. This right of association is a "basic constitutional freedom" that, "like free speech, lies at the foundation of a free society." Buckley v. Valeo, 424 U.S. 1 (1976) (quoting Kusper v. Pontikes, 414 U.S. 51 (1973), and Shelton v. Tucker, 364 U.S. 479, 486 (1960)). Infringement upon this type of freedom to associate -- the type that is instrumental to protecting First Amendment freedoms -- is subject to the closest scrutiny. The State must demonstrate a compelling or overriding interest "and employ means closely drawn to avoid unnecessary abridgement." Buckley, 424 U.S. at 25; see also Roberts, 468 U.S. at 623. In Roberts v. United States Jaycees, the Court upheld the Minnesota Supreme Court's interpretation of the state's public accommodations statute because the court adopted "commonly used and sufficiently precise standards" and applied constructions that would exclude private groups from the statute's reach. 468 U.S. at 631. The Court determined that the "sufficiently precise standards" included "a number of specific and objective criteria - regarding the organization's size, selectivity, commercial nature, and use of public facilities - typically employed in determining the applicability of state and federal antidiscrimination statutes to the membership policies of assertedly private clubs." Id. at 629. Thus, the statute, explained the United States Supreme Court, "does not create an unacceptable risk of application to a substantial amount of protected conduct." Id. at 631.