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Keywords

contractjurisdictionappealtrialdeclaratory judgment
plaintiffdefendantdeclaratory judgment

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Gulf South Conference v. Boyd, 369 So.2d 553

Facts

Julian R. Boyd, a university student, filed a complaint for a declaratory judgment against the Gulf South Conference (GSC) to declare his eligibility to participate in varsity football at Troy State University. Boyd had previously attended Livingston University on a one-year football scholarship, which was not renewed after he declined the offer to return. After graduating from Enterprise State Junior College, Boyd sought to transfer to Troy State but was ruled ineligible by the GSC. The trial court found that Boyd was eligible to play football under the GSC bylaws, leading to the appeal by the GSC.

On July 12, 1977 the plaintiff Boyd filed his original complaint for a declaratory judgment against the defendant, Gulf South Conference (hereinafter called GSC), asking that the court declare him eligible to participate in varsity football at Troy State University.

Issue

Whether Julian R. Boyd is eligible to participate in varsity football at Troy State University under the Gulf South Conference bylaws.

Whether Julian R. Boyd is eligible to participate in varsity football at Troy State University under the Gulf South Conference bylaws.

Rule

The right to participate in college athletics is considered a property right of present economic value. The general noninterference doctrine concerning voluntary associations does not apply to disputes between college athletes and athletic associations. A bona fide justiciable controversy must exist for a court to have jurisdiction in declaratory judgment actions.

The right to be eligible to participate in college athletics cannot be viewed as mere speculative interest, but is a property right of present economic value.

Analysis

The court analyzed the GSC bylaws and determined that Boyd's situation qualified him as a free agent since he did not accept the renewal of his scholarship from Livingston University. The court emphasized that the relationship between a college athlete and the institution is contractual, and Boyd's refusal to accept the scholarship renewal did not obligate him to remain ineligible. The court concluded that Boyd's eligibility was supported by the bylaws, which allowed him to transfer and play at another GSC school after not participating for two years.

The general noninterference doctrine concerning voluntary associations does not apply to cases involving disputes between college athletes themselves and college athletic associations.

Conclusion

The court affirmed the trial court's decision, declaring that Boyd was eligible to participate in varsity football at Troy State University.

We affirm.

Who won?

Julian R. Boyd prevailed in this case as the court ruled in his favor, affirming his eligibility to participate in varsity football. The court found that Boyd's right to compete was a property right of present economic value, distinguishing it from high school athletics where such rights are not recognized. The court also noted that the GSC's interpretation of its bylaws was incorrect, as Boyd had become a free agent due to the non-renewal of his scholarship, allowing him to sign with any other GSC school.

Boyd was entitled to the relief requested. The court therefore ordered that Boyd was eligible to participate in varsity football at Troy State University for the 1978-1979 football season provided Boyd was a student in good standing and enrolled at the Troy, Alabama campus of Troy State University for the Fall Term 1978.

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