Lonnie J. Shelton v. The National Collegiate Athletic Association, an Association
1976 U.S. App. LEXIS 12743, 539 F.2d 1197 (1976)
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Rule of Law:
A rule from a voluntary athletic association that declares a student-athlete ineligible upon signing a professional contract, regardless of the contract's subsequent legal enforceability, does not violate the Equal Protection Clause because it is rationally related to the legitimate purpose of preserving amateurism in intercollegiate athletics.
Facts:
- The National Collegiate Athletic Association (NCAA) has a constitutional rule intended to preserve amateurism in college sports.
- The rule states that a student who signs a contract to play a professional sport is ineligible to participate in that intercollegiate sport.
- A student-athlete, Shelton, signed a professional contract with an American Basketball Association team.
- As a result of signing the contract, Oregon State University declared Shelton ineligible to participate in intercollegiate basketball.
- Shelton contends that he was induced to sign the contract by fraud and undue influence, making it unenforceable.
- Shelton filed a separate lawsuit against the professional team to determine the legal enforceability of the contract, which was pending at the time of this case.
Procedural Posture:
- Shelton sued the NCAA in a federal district court.
- Shelton sought a preliminary injunction to prevent the NCAA from enforcing its eligibility rule against him while his other lawsuit regarding the contract's validity was pending.
- The district court (the trial court) granted the preliminary injunction in favor of Shelton.
- The NCAA, as the appellant, appealed the district court's grant of the preliminary injunction to the United States Court of Appeals for the Ninth Circuit.
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Issue:
Does the NCAA rule, which declares a student-athlete ineligible for intercollegiate athletics in a sport upon signing a professional contract to play that sport, regardless of the contract's legal enforceability, violate the Equal Protection Clause?
Opinions:
Majority - Wright, J.
No. The NCAA rule does not violate the Equal Protection Clause because it is rationally related to a legitimate purpose. The court applied the rational basis test, as no fundamental right was at stake. The stated goal of promoting and protecting amateurism in intercollegiate athletics is a legitimate one. The rule, which uses the act of signing a professional contract as a clear line for determining professional status, is a rational means of achieving that goal. The court reasoned that alternatives, such as requiring the NCAA to determine the legal enforceability of each contract, would be overly burdensome, impractical, and would undermine the distinction between amateur and professional athletes. While the rule may produce unfortunate results in some cases, such as for an athlete whose contract is later deemed void, this potential hardship does not render the rule irrational.
Analysis:
This decision solidifies the significant deference courts grant to the rules of voluntary associations like the NCAA under the rational basis standard of review. It establishes that a rule can be 'overinclusive' and still withstand an equal protection challenge, provided the classification is rationally related to a legitimate objective. The court's acceptance of administrative convenience and the need for a clear, easily applied standard as a rational basis has significant implications, reinforcing the idea that such practical considerations can justify rules that may seem harsh in individual circumstances. This precedent signals to student-athletes that the act of signing a professional contract carries immediate and severe eligibility consequences, which cannot be stayed by later challenging the contract's validity.
