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Keywords

plaintiffdefendanthearingmotionsummary judgmentdue processmotion for summary judgment

plaintiffdefendantmotionsummary judgmentdue processmotion for summary judgment

Related Cases

Kulovitz v. Illinois High School Ass’n, 462 F.Supp. 875

Facts

The plaintiff, a high school student, moved to Scottsdale, Arizona, and later returned to Thornwood High School in Illinois without his parents. He was found ineligible to participate in interscholastic athletics due to a transfer rule that required students who transfer without their parents to be ineligible for one year. The plaintiff challenged this rule, claiming it violated his due process and equal protection rights. A hearing was conducted where he was allowed to present evidence and cross-examine witnesses, but the Board upheld the decision of ineligibility.

During 1975 through 1977, plaintiff was a student at Thornwood. In November, 1977 he moved to Scottsdale, Arizona. Due to academic difficulties, plaintiff was found to be ineligible for participation in athletics until the second semester of the 1978-1979 school year. Upon attaining the age of 18, plaintiff returned in June, 1978 to the Thornwood School District without his parents and took up residency with his grandmother.

Issue

Did the high school association's transfer rule violate the student's due process and equal protection rights?

Rule

Participation in interscholastic athletics is not a constitutionally protected civil right. A party claiming deprivation of due process must establish a property interest by reference to state law or custom. An expectation of an athletic scholarship does not constitute a protected property interest. The transfer rule, which prevents certain students from participating in athletics for one year, is evaluated under the rational basis standard, which considers the classification's character, individual interests affected, and governmental interests.

Participation in interscholastic athletics is not a constitutionally protected civil right. A party claiming deprivation of due process protected interest may establish existence of property interest by reference to state law or custom. U.S.C.A.Const. Amends. 5, 14.

Analysis

The court found that the plaintiff did not have a constitutionally protected property right in participating in interscholastic athletics or in obtaining a college athletic scholarship. The transfer rule was deemed rational as it served the legitimate state interest of preventing district hopping and ensuring fair competition. The plaintiff was afforded more than minimal due process during the eligibility hearing, where he could present witnesses and make arguments.

The educational process is a broad and comprehensive concept with a variable and indefinite meaning. It is not limited to classroom attendance but includes innumerable separate components, such as participation in athletic activity and membership in school clubs and social groups, which combine to provide an atmosphere of intellectual and moral advancement. We do not read Goss to establish a property interest subject to constitutional protection in each of these separate components.

Conclusion

The court granted the defendant's motion for summary judgment, concluding that the transfer rule did not violate the plaintiff's constitutional rights.

Accordingly, defendant's motion for summary judgment is granted and this case is dismissed. Judgment is entered for the defendant.

Who won?

The Illinois High School Association prevailed in this case as the court found that the transfer rule was rationally related to a legitimate state interest and that the plaintiff was afforded adequate due process during the hearings. The court determined that the plaintiff's claims of constitutional violations were without merit, leading to the dismissal of his case.

Since plaintiff has failed to state a valid constitutional claim, the court grants defendant's motion for summary judgment and dismisses the case.

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