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Keywords

plaintiffdefendantinjunctiondiscrimination

injunction

Related Cases

Washington v. Indiana High School Athletic Ass’n, Inc., 181 F.3d 840, 136 Ed. Law Rep. 713, 9 A.D. Cases 804, 15 NDLR P 247

Facts

Eric Washington, a learning disabled student at Central Catholic High School in Lafayette, Indiana, faced ineligibility under the Indiana High School Athletic Association's (IHSAA) eight-semester rule, which limited athletic eligibility to the first eight semesters following the commencement of ninth grade. Washington had been held back in eighth grade and subsequently dropped out of high school due to academic struggles. After being tested and diagnosed with a learning disability, he sought a waiver from the IHSAA to allow him to play basketball, which was denied. Washington and Central Catholic filed for a preliminary injunction against the IHSAA's enforcement of the rule, claiming it violated the Americans with Disabilities Act (ADA).

Issue

Did the IHSAA's enforcement of the eight-semester eligibility rule violate the Americans with Disabilities Act by denying a waiver to a learning disabled student?

Rule

Under the Americans with Disabilities Act (ADA), a public entity may not discriminate against individuals with disabilities in programs or activities. Discrimination can be established by showing that a defendant refused to provide a reasonable modification to a rule that disproportionately impacts disabled individuals. A plaintiff must demonstrate that they are a qualified individual with a disability and that the requested modification does not fundamentally alter the nature of the program.

Analysis

The court found that Washington was likely to succeed on the merits of his claim under the ADA, as he demonstrated a causal connection between his learning disability and his ineligibility under the eight-semester rule. The court noted that the IHSAA's refusal to grant a waiver constituted a failure to make a reasonable accommodation, as it did not fundamentally alter the purpose of the rule. The court also emphasized that Washington's participation in athletics could enhance his academic motivation and self-esteem, which aligned with the ADA's intent to provide equal opportunities.

Conclusion

The court affirmed the district court's decision to grant a preliminary injunction, allowing Washington to participate in high school basketball despite the IHSAA's eight-semester rule.

We affirm the district court's decision to grant the preliminary injunction.

Who won?

Eric Washington and Central Catholic High School prevailed in their action against the IHSAA. The court determined that the IHSAA's enforcement of the eight-semester rule, without granting a waiver for Washington's learning disability, constituted discrimination under the ADA. The court found that Washington was likely to succeed on the merits of his claim, and the balance of interests favored granting the preliminary injunction, as the potential harm to Washington outweighed any burden on the IHSAA.

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