Letendre Ex Rel. Letendre v. Missouri State High School Activities Ass'n
2002 WL 1543110, 2002 Mo. App. LEXIS 1533, 86 S.W.3d 63 (2002)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A state high school athletic association by-law prohibiting students from competing on both school and non-school teams in the same sport during the same season does not violate the Equal Protection Clause or the First Amendment right to free association, provided the rule is rationally related to a legitimate state interest.
Facts:
- Claire Letendre was a 15-year-old high school sophomore at St. Joseph's Academy, a member of the Missouri State High School Activities Association (MSHSAA).
- Letendre had been a competitive swimmer with the private Parkway Swim Club since age five, practicing and competing with the club year-round.
- MSHSAA By-law 235 prohibited a student from practicing or competing with a non-school team in the same sport during the school team's season.
- Letendre attended meetings for her high school's swim team and was informed about the MSHSAA eligibility rules.
- After the school swim season officially began, Letendre chose to continue practicing with her private swim club rather than her high school team.
- As a result of her choice, MSHSAA's by-law rendered her ineligible to compete for her high school swim team.
Procedural Posture:
- Claire Letendre filed a suit seeking injunctive relief against the Missouri State High School Activities Association (MSHSAA) in a state trial court.
- The trial court conducted a trial on the merits of the case.
- The trial court denied Letendre's request for injunctive relief and dismissed her lawsuit with prejudice.
- Letendre, as appellant, appealed the trial court's judgment to the Missouri Court of Appeals, Eastern District.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a state high school athletic association's by-law, which prohibits students from competing on both a school team and a non-school team in the same sport during the same season, violate the Equal Protection Clause of the Fourteenth Amendment or the First Amendment right of free association?
Opinions:
Majority - James R. Dowd
No. The MSHSAA by-law prohibiting simultaneous participation on a school and non-school team in the same sport does not violate the Equal Protection Clause or the First Amendment right of free association. For the Equal Protection claim, because participation in high school athletics is not a fundamental right and the rule does not involve a suspect classification, the court applies the rational basis standard of review. The MSHSAA presented several legitimate interests for the rule, including preventing interference with academics, promoting competitive equity, avoiding coaching conflicts, and discouraging overemphasis on athletics. The court found that the by-law is rationally related to these legitimate goals. Regarding the First Amendment claim, the right of association protects only intimate relationships and expressive activities for political or religious purposes. The court concluded that simultaneous participation on two swim teams does not fall into either of these protected categories, and therefore, no constitutional right is burdened by the rule.
Analysis:
This decision reinforces the significant judicial deference granted to the rulemaking authority of voluntary high school athletic associations. By applying the lenient rational basis test, the court signals that such eligibility rules will be upheld against constitutional challenges as long as the association can articulate any conceivable legitimate purpose. The ruling solidifies the legal principle that participation in extracurricular athletics is a privilege, not a fundamental right, thereby setting a high bar for students seeking to challenge such regulations. It also narrowly defines the scope of the First Amendment's right of association, clarifying that it does not extend to participation in multiple sports teams.
