McAdoo v. University of North Carolina
2013 WL 149694, 2013 N.C. App. LEXIS 70, 225 N.C. App. 50 (2013)
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Rule of Law:
A student-athlete's claim for damages based on speculative future professional earnings resulting from an ineligibility determination is not justiciable due to lack of standing. Furthermore, such claims become moot once the athlete signs a professional contract, as the relief sought (a professional career) has been effectively obtained.
Facts:
- Michael McAdoo was a football player at the University of North Carolina at Chapel Hill (UNC) on an athletic scholarship.
- During his time at UNC, McAdoo received academic assistance from a university-paid tutor, Jennifer Wiley.
- In July 2009, McAdoo sought Wiley's help on a paper for a Swahili class, emailing her the draft and a list of sources; Wiley completed the footnotes and Works Cited sections for him.
- In 2010, during an unrelated NCAA investigation, UNC discovered communications between McAdoo and Wiley that suggested potential academic dishonesty.
- UNC reported the potential academic violation to the NCAA. Subsequently, UNC's internal Honor Court found McAdoo guilty of an honor code violation for the Swahili paper, resulting in academic probation and a one-semester suspension.
- On November 12, 2010, the NCAA declared McAdoo permanently ineligible for intercollegiate athletics, citing academic fraud and receipt of other improper benefits.
- An NCAA committee upheld the permanent ineligibility ruling after an appeal hearing in December 2010.
- In August 2011, McAdoo entered the NFL's supplemental draft and later signed a professional contract as a free agent with the Baltimore Ravens.
Procedural Posture:
- Michael McAdoo (Plaintiff) filed a complaint against UNC, its Chancellor, and the NCAA in Durham County Superior Court, a state trial court.
- McAdoo filed an amended complaint seeking damages, declaratory judgment, and injunctive relief.
- The trial court denied McAdoo's motion for a preliminary injunction and petition for a writ of mandamus.
- All defendants filed motions to dismiss the amended complaint for lack of subject matter jurisdiction and failure to state a claim.
- On November 23, 2011, the trial court granted the defendants' motions and dismissed McAdoo's complaint in its entirety.
- McAdoo (as Appellant) appealed the dismissal to the North Carolina Court of Appeals, an intermediate appellate court.
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Issue:
Does a student-athlete present a justiciable controversy when suing his university and the NCAA for declaring him ineligible, where the alleged damages are the speculative loss of future professional earnings and the athlete has subsequently signed a professional contract?
Opinions:
Majority - Hunter, Jr., J.
No, a student-athlete does not present a justiciable controversy under these circumstances because the claims lack standing and are moot. To be justiciable, a claim must present a real, existing controversy that a court can effectively resolve. McAdoo's claims fail this test for two primary reasons. First, he lacks standing because his alleged injury—the potential loss of greater earnings in a professional football career—is too hypothetical and speculative for a court to measure with reasonable certainty. Precedent from North Carolina and other jurisdictions consistently rejects claims for damages based on the loss of a potential professional athletic career as non-justiciable. Second, his claims are moot because he has effectively obtained the ultimate relief he sought by signing a professional contract with an NFL team. Since he is now a professional football player, any court decision regarding his college eligibility would have no practical effect on the existing controversy, rendering the issue abstract.
Analysis:
This decision reinforces the judiciary's significant deference to the internal governance of voluntary associations like the NCAA and academic institutions, particularly in eligibility disputes. It establishes a high barrier for student-athletes seeking damages for lost professional opportunities, categorizing such potential losses as inherently speculative and therefore non-justiciable. The ruling also solidifies the application of the mootness doctrine in this context, effectively foreclosing litigation once an athlete turns professional, as the court deems the core objective of securing a professional career to have been achieved, regardless of the path taken.
