Georgia High School Association v. Waddell
285 S.E.2d 7, 1981 Ga. LEXIS 1097, 248 Ga. 542 (1981)
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Rule of Law:
Courts of equity lack the authority to review the on-field decisions of high school sports referees, as such decisions do not present justiciable controversies and do not implicate a player's constitutionally protected property or equal protection rights.
Facts:
- On October 23, 1981, R. L. Osborne High School and Lithia Springs High School played a football game to determine which team would advance to the regional playoffs.
- With 7 minutes and 1 second remaining, Osborne was leading 7-6 and punted the ball.
- The referee called a 'roughing the kicker' penalty on Lithia Springs.
- According to the rules, the penalty should have been 15 yards and an automatic first down for Osborne.
- The referee correctly assessed the 15-yard penalty but incorrectly failed to award the automatic first down, instead ruling it was 4th down.
- Following the incorrect ruling, Osborne punted the ball again.
- Lithia Springs then gained possession, scored a field goal, and later intercepted a pass for another score.
- The final score was Lithia Springs 16, Osborne 7, eliminating Osborne from the playoffs.
Procedural Posture:
- Osborne filed a protest with the Executive Secretary of the Georgia High School Association (GHSA), who denied it.
- Osborne appealed to the GHSA's Hardship Committee, which affirmed the denial.
- Osborne then appealed to the GHSA's state Executive Committee, which also affirmed the denial.
- Parents of Osborne players (plaintiffs-appellees) sued the GHSA (defendant-appellant) in the Superior Court of Cobb County, a trial court.
- The trial court found that it had jurisdiction and that the players' rights were violated.
- The trial court issued an order canceling the scheduled playoff game and commanding Osborne and Lithia Springs to resume their game from the point of the referee's error.
- The GHSA filed a motion for supersedeas (a stay) in the Supreme Court of Georgia, asking the court to suspend the trial court's order pending a final decision.
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Issue:
Does a referee's misapplication of a game rule create a justiciable controversy or violate a player's constitutional rights, thereby allowing judicial intervention to overturn the outcome of a high school football game?
Opinions:
Majority - Per curiam
No, a referee's misapplication of a game rule does not create a justiciable controversy or violate a player's constitutional rights allowing for judicial intervention. Courts of equity in Georgia are without authority to review decisions of football referees because those decisions do not present judicial controversies. Citing its precedent in Smith v. Crim, the court reaffirmed that a high school athlete has no protectable property interest in participating in interscholastic sports that would give rise to a due process claim. Furthermore, a referee's error does not constitute a denial of equal protection, as holding otherwise would illogically imply that any error made in a court of law would also be an equal protection violation. The court's role is not to act as a super-referee for athletic contests.
Analysis:
This decision establishes a firm judicial non-intervention policy regarding on-field officiating disputes in amateur athletics in Georgia. It solidifies the legal principle that participation in high school sports is a privilege, not a constitutionally protected right, thereby preventing courts from being inundated with lawsuits over game-related errors. By declaring such disputes non-justiciable, the court preserves the autonomy of athletic associations to govern their own affairs and ensures finality in the outcomes of sporting events. This precedent makes it exceptionally difficult for a party to succeed in challenging the result of a game in court based on a referee's mistake.
