Parish v. National Collegiate Athletic Association
361 F. Supp. 1220, 1973 U.S. Dist. LEXIS 12473 (1973)
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Rule of Law:
Participation in intercollegiate athletics is not a constitutionally protected interest, and therefore an athletic association's eligibility rule does not violate the Equal Protection or Due Process Clauses of the Fourteenth Amendment so long as it is rationally related to a legitimate purpose, such as maintaining academic standards.
Facts:
- Robert L. Parish, a highly sought-after high school basketball prospect, and other student-athletes were recruited to play for Centenary College on athletic scholarships.
- Centenary College was a voluntary member of the National Collegiate Athletic Association (NCAA), an association that sets rules for its member institutions.
- The NCAA's '1.600 Rule' required member institutions to limit first-year athletic eligibility to students who were predicted to achieve at least a 1.600 grade-point average, based on a formula using high school grades and scores from the SAT or ACT.
- Parish's ACT scores were too low to predict a 1.600 GPA under the NCAA's formula.
- NCAA rules explicitly prohibited institutions from converting ACT scores to SAT scores to meet the eligibility requirement.
- Despite being warned orally and in writing by the NCAA that converting scores was prohibited, Centenary's athletic department used a conversion table to certify Parish and the other plaintiffs as eligible.
- Centenary signed Parish to a scholarship contract on August 17, 1972.
- Despite failing to meet the predictive 1.600 requirement, Parish and the other plaintiffs actually earned grade-point averages higher than 1.600 during their time at Centenary.
Procedural Posture:
- Student basketball players at Centenary College, led by Robert Parish, filed a lawsuit against the NCAA in the U.S. District Court for the Western District of Louisiana.
- The plaintiffs sought a preliminary and permanent injunction to stop the NCAA from enforcing its 1.600 Rule, which would declare them ineligible.
- The district court granted a temporary restraining order, which it later extended but ultimately allowed to expire.
- The NCAA filed motions to dismiss the case, which the district court denied.
- The court ordered that Centenary College be added to the lawsuit as a party plaintiff.
- A hearing was held on the plaintiffs' application for a declaratory judgment and a preliminary injunction.
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Issue:
Does the NCAA's '1.600 Rule,' which requires student-athletes to predict a minimum 1.600 grade point average based on high school performance and standardized test scores to be eligible for intercollegiate competition, violate the Equal Protection or Due Process Clauses of the Fourteenth Amendment?
Opinions:
Majority - Dawkins, Chief Judge
No, the NCAA's '1.600 Rule' does not violate the Equal Protection or Due Process Clauses of the Fourteenth Amendment. The court held that there is no substantial federal question because the privilege of participating in interscholastic athletics is not a fundamental right protected by the Constitution. Under the Due Process Clause, citing Board of Regents v. Roth, the court found the athletes had no constitutionally protected 'property interest' in playing sports, but rather a mere expectation. Therefore, the rule is evaluated under the rational basis test for equal protection purposes. The NCAA's stated goals—ensuring athletes are part of the student body, preventing academic exploitation, and maintaining athletics as part of the educational program—are legitimate state purposes. The 1.600 Rule, by establishing a minimum academic prediction, is rationally related to achieving these goals. The court concluded that even if the rule produces harsh or seemingly unreasonable results in isolated cases, it does not render the rule unconstitutional under the deferential standard of rational basis review.
Analysis:
This decision solidifies the legal principle that participation in intercollegiate athletics is a privilege, not a constitutionally protected right, thereby affording athletic governing bodies like the NCAA significant deference in setting eligibility rules. By applying the rational basis test, the court makes it exceedingly difficult for student-athletes to challenge academic eligibility standards on constitutional grounds. This precedent reinforces the authority of athletic associations to regulate academic performance as a condition of participation, limiting federal court intervention unless a rule is shown to be completely irrational or based on a suspect classification.
