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Keywords

lawsuitinjunctionappealtrial
plaintiffinjunctiontrialmotion

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Zuments by Zuments v. Colorado High School Activities Ass’n, 737 P.2d 1113, 40 Ed. Law Rep. 475

Facts

This case involves a lawsuit brought by five student athletes from various Colorado public high schools against the Colorado High School Activities Association (CHSAA). The students sought to prevent the enforcement of the 'outside competition' rule, which prohibited them from practicing with non-school teams and participating in interscholastic athletics unless they obtained a waiver. The trial court initially granted a preliminary injunction to the students, finding that the rule violated their rights to freedom of association and equal protection. However, the CHSAA appealed the decision.

This action was brought on behalf of five student athletes enrolled in various Colorado public high schools against CHSAA, a voluntary, unincorporated association of public and private high schools in Colorado which serves as the central governing body for interscholastic athletics and other activities among its member schools.

Issue

Did the enforcement of the 'outside competition' rule by the CHSAA violate the students' constitutional rights to equal protection and freedom of association?

Did the enforcement of the 'outside competition' rule by the CHSAA violate the students' constitutional rights to equal protection and freedom of association?

Rule

The 'outside competition' rule prohibits student athletes from competing on non-school teams during their sports season unless they obtain a waiver. The court applied the rational basis test to determine if the rule furthered legitimate state interests, such as fairness in athletics and the well-being of student athletes. The court found that the rule did not violate the students' constitutional rights as it did not prevent them from associating with non-school teams but required them to choose between competing for their school or non-school teams.

The 'outside competition' rule provides: 'Players certified to participate as members of any high school sport may not compete on any other team, nor in any non-school activity or event in that sport during that sports season…. [A]ny player who does so participate in violation of this rule shall not be eligible to participate in a specific or all interscholastic athletic activities for a period of time to be determined by the [CHSAA] Commissioner.'

Analysis

The court analyzed the application of the 'outside competition' rule under the rational basis test, concluding that the rule was not arbitrary or capricious. The evidence showed that waivers were uniformly granted to all applicants, and there was no instance of unequal treatment. The court determined that the rule served legitimate state purposes, including promoting fairness and ensuring student athletes' well-being, thus upholding the CHSAA's enforcement of the rule.

Under the outside competition rule, student athletes are not prohibited from associating and practicing with other teams. The rule merely requires that during a high school sport's season, students must choose between competing on their school team or competing on non-school teams. We do not find this to be an impermissible burden on their constitutional right of freedom of association.

Conclusion

The court reversed the trial court's decision, concluding that the 'outside competition' rule did not violate the students' constitutional rights and that the preliminary injunction was improperly granted.

Accordingly, the order of the trial court granting plaintiffs a preliminary injunction is reversed, and the cause is remanded for further proceedings.

Who won?

The Colorado High School Activities Association (CHSAA) prevailed in this case. The court found that the enforcement of the 'outside competition' rule was justified and did not violate the students' constitutional rights. The court emphasized that the rule was applied uniformly and rationally, serving legitimate state interests in maintaining fairness in interscholastic athletics and protecting student athletes from over-competition.

CHSAA argues that the court's finding of arbitrary application of the waiver provision is unsupported by the record and that, therefore, the court erred in granting plaintiff's motion for the preliminary injunction. We agree.

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