Brands v. Sheldon Community School
42 Educ. L. Rep. 753, 1987 U.S. Dist. LEXIS 12032, 671 F. Supp. 627 (1987)
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Rule of Law:
A student's interest in participating in interscholastic athletics is a mere expectation rather than a constitutionally protected property or liberty interest, and therefore, suspension from an extracurricular activity does not trigger the full protections of the Due Process Clause.
Facts:
- The plaintiff was a high school student and a defending state champion wrestler with a nearly perfect competitive record.
- The plaintiff and his twin brother had attracted attention from college coaches and hoped to receive college wrestling scholarships.
- On January 25, 1987, the plaintiff and three other male students allegedly engaged in multiple acts of sexual intercourse with a 16-year-old female student at the plaintiff's home.
- Rumors about the incident spread throughout Sheldon Community High School.
- Following an investigation, the school principal, David Kapfer, determined the plaintiff's conduct was detrimental to the school's best interests.
- The principal declared the plaintiff ineligible for the remainder of the wrestling season, which included sectional, district, and state tournaments.
Procedural Posture:
- The Sheldon Community High School principal declared the plaintiff ineligible for the remainder of the wrestling season.
- The plaintiff appealed the principal's decision to the Superintendent, who affirmed the decision.
- The plaintiff then appealed to the Sheldon Community School Board.
- The School Board held a closed evidentiary hearing and subsequently affirmed the administration's decision to suspend the plaintiff.
- The plaintiff filed a complaint in the U.S. District Court, seeking a temporary restraining order (TRO) and a preliminary injunction against the school district.
- The District Court granted an initial TRO to allow the plaintiff to compete in a sectional tournament, which then expired before the hearing on the preliminary injunction.
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Issue:
Does a high school student's interest in participating in interscholastic athletics, even with the potential for a college scholarship, constitute a property or liberty interest protected by the Fourteenth Amendment's Due Process Clause?
Opinions:
Majority - O’Brien, Chief Judge
No. A student's interest in participating in interscholastic athletics is not a protected property or liberty interest under the Fourteenth Amendment. The court reasoned that a clear majority of federal courts have held that a student's interest in participating in athletics is a 'mere expectation' rather than a 'constitutionally protected claim of entitlement.' The potential for a college scholarship does not change the nature of the interest at stake; it merely increases its value but does not create a legitimate claim of entitlement. Because no protected interest exists, the procedural protections of the Due Process Clause are not triggered. Even if an interest were recognized, the court found the plaintiff received all process he was due, including notice, an opportunity to be heard, and a lengthy evidentiary hearing before the school board. The court also rejected the plaintiff's substantive due process claim, finding the school board's decision was not arbitrary or capricious, as schools have a legitimate interest in disciplining students, especially student leaders, for off-campus conduct that disrupts the school and is contrary to community mores.
Analysis:
This decision solidifies the widely held legal doctrine that participation in extracurricular activities is a privilege, not a constitutionally protected right. It significantly limits a student's ability to challenge a school's disciplinary decisions regarding athletics in federal court on due process grounds. The ruling clarifies that the potential for significant financial gain, such as a college scholarship, does not elevate a 'mere expectation' into a protected property interest. This precedent gives school districts broad authority to regulate the off-campus conduct of student-athletes and other student leaders who are seen as representatives of the school.
