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respondent

Related Cases

Brentwood Academy v. Tennessee Secondary School Athletic Ass’n, 531 U.S. 288, 121 S.Ct. 924, 148 L.Ed.2d 807, 151 Ed. Law Rep. 18, 01 Cal. Daily Op. Serv. 1435, 2001 Daily Journal D.A.R. 1793, 14 Fla. L. Weekly Fed. S 74

Facts

Respondent not-for-profit athletic association (Association) regulates interscholastic sport among Tennessee public and private high schools. Most of the State's public high schools are members, representing 84% of the Association's membership.

Issue

Whether the Tennessee Secondary School Athletic Association's enforcement of a recruiting rule against a member school constitutes state action under the Fourteenth Amendment.

The issue is whether a statewide association incorporated to regulate interscholastic athletic competition among public and private secondary schools may be regarded as engaging in state action when it enforces a rule against a member school.

Rule

A private entity's actions may be considered state action for Fourteenth Amendment purposes if there is a close nexus between the state and the challenged action, allowing seemingly private behavior to be treated as that of the state itself. This includes situations where the private entity is entwined with governmental policies or when government is involved in its management or control.

Analysis

The Supreme Court found that the TSSAA's actions were state actions due to the pervasive entwinement of public school officials in its structure. With 84% of its membership being public schools, the TSSAA operated with significant input and control from public school administrators, who were involved in decision-making processes. The court emphasized that the TSSAA's regulatory role was integral to the public education system in Tennessee, thus justifying the application of constitutional standards.

The necessarily fact-bound inquiry leads to the conclusion of state action here. The Association's nominally private character is overborne by the pervasive entwinement of public institutions and public officials in its composition and workings, and there is no substantial reason to claim unfairness in applying constitutional standards to it.

Conclusion

The Supreme Court reversed the Sixth Circuit's decision, holding that the TSSAA's regulatory activities constituted state action under the Fourteenth Amendment.

Held: The Association's regulatory activity is state action owing to the pervasive entwinement of state school officials in the Association's structure, there being no offsetting reason to see the Association's acts in any other way.

Who won?

The Supreme Court ruled in favor of Brentwood Academy, concluding that the TSSAA's enforcement of its recruiting rule was state action. The court's reasoning highlighted the significant involvement of public school officials in the TSSAA's operations, which warranted the application of constitutional standards to the Association's actions.

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