Cruz Ex Rel. Cruz v. Pennsylvania Interscholastic Athletic Ass'n
157 F. Supp. 2d 485, 2001 WL 722560, 2001 U.S. Dist. LEXIS 8669 (2001)
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Rule of Law:
Under the Americans with Disabilities Act (ADA), a state interscholastic athletic association's maximum age-eligibility rule, if it lacks a waiver provision, is invalid because it fails to provide for an individualized inquiry into whether waiving the rule for a specific student with a disability would fundamentally alter the nature of the competition.
Facts:
- Luis Cruz is a student with learning disabilities who, due to his disability, entered elementary school between ages eleven and twelve and was retained for two additional years.
- Cruz participated in football, wrestling, and track during his first three years at Ridley High School, and his Individualized Education Programs (IEPs) noted that this participation was important for his socialization and educational outcomes.
- On June 2, 2000, Cruz turned 19 years old, which was 28 days before the July 1 cutoff date established by the Pennsylvania Interscholastic Athletic Association (P.I.A.A.).
- The P.I.A.A.'s 'Age Rule' renders a student ineligible for interscholastic athletics upon turning 19, unless their birthday falls on or after July 1 of that school year.
- The P.I.A.A.'s Age Rule contains no provision for a waiver or exception for any reason, including disability.
- After Cruz played in two football games during his fourth year, Ridley High School officials discovered the conflict with the Age Rule and reported it.
- Ridley High School requested that the P.I.A.A. grant a waiver for Cruz or amend the rule to allow for one.
- The P.I.A.A. Board of Directors unanimously rejected the request to amend the rule and provide for a waiver.
Procedural Posture:
- Luis Cruz and Ridley School District filed a Complaint and Petition for Preliminary Injunction against the P.I.A.A. in the United States District Court for the Eastern District of Pennsylvania.
- The district court held a hearing on the request for a preliminary injunction on November 15, 2000.
- Following the hearing, the court issued a bench ruling denying the preliminary injunction, finding that the plaintiffs had not demonstrated immediate, irreparable harm.
- The parties subsequently stipulated to have the court decide the request for a permanent injunction on the record from the prior hearing and submitted briefs.
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Issue:
Does the Pennsylvania Interscholastic Athletic Association's (P.I.A.A.) maximum age rule, which does not provide for a waiver, violate the Americans with Disabilities Act (ADA) when applied to a student whose age ineligibility is a direct result of his learning disability?
Opinions:
Majority - Buckwalter, District Judge
Yes, the P.I.A.A.'s inflexible Age Rule violates the Americans with Disabilities Act (ADA) because it fails to allow for a reasonable modification through an individualized assessment. The court's analysis relies heavily on the Supreme Court's decision in PGA Tour, Inc. v. Martin, which established that the ADA requires an individualized inquiry to determine if a requested modification is reasonable, necessary for the disabled individual, and would not fundamentally alter the nature of the activity. Applying that test, the court found that waiving the age rule for Cruz would be a necessary and reasonable modification for his participation in football and track. Given Cruz's small stature, limited experience, and marginal skill level in those sports, his participation would not fundamentally alter the nature of the competition or create an unfair advantage. The P.I.A.A.'s argument that creating a waiver process would impose an undue administrative burden was rejected, as the organization already manages waiver systems for other complex rules, such as those regarding transfers and semesters of eligibility.
Analysis:
This decision aligns the district with the legal interpretation of the ADA, post-PGA Tour, Inc. v. Martin, that favors individualized assessments over the rigid application of general rules. It solidifies the principle that an organization cannot simply declare a rule 'essential' to avoid its duty to provide reasonable accommodations. By requiring an athletic association to implement a waiver process for its age rule, the court places the burden on the association to demonstrate, on a case-by-case basis, that a specific accommodation would fundamentally alter the competition. This precedent significantly strengthens the position of student-athletes with disabilities who are rendered ineligible by neutral rules that do not account for the impact of their disability.
