FLORIDA HIGH SCHOOL ACTIVITIES ASSOCIATION, INC., APPELLANT,
v.
AARON BRYANT, APPELLEE

Fla. 3d DCA | 1975-05-13
No. 75-18
Before BARKDULL, C. J., HENDRY, J., and CHARLES CARROLL (Ret.), Associate Judge.
313 So. 2d 57 Florida District Court of Appeal, Third District (1975) Caution
Cited by 6 cases

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Synopsis

The Florida High School Activities Association appealed a trial court judgment declaring student Aaron Bryant eligible to participate in basketball despite the Association's four-year eligibility rule. The appellate court affirmed the trial court's finding that Bryant qualified as a hardship case and that enforcing the rule would be arbitrary and unsupported by evidence.


Holding

The four-year eligibility rule should not be applied arbitrarily to exclude a student who qualifies as a hardship case, particularly where the evidence supports that athletics are vital to the student's development and no redshirting is involved.


Headnotes

[1] A four-year eligibility rule for interscholastic athletics may not be arbitrarily invoked to exclude a student who qualifies as a hardship case.

[2] A student's participation in interscholastic athletics can be considered vital to their general scholastic and social development, including rehabilitation from prior pro…

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Key Quotes

“it is an important and vital part of his life providing an impetus to his general scholastic and social development and rehabilitation from his prior problems as a juvenile delinquent. It has resulted in the improvement of his grades, attitude, self-confidence, discipline and maturity.”

The trial court's finding that basketball was essential to Bryant's development, supporting the hardship exception

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Facts & Procedural History

Aaron Bryant, a senior at Miami Jackson Senior High School, sought to participate in interscholastic basketball during the 1974-75 school year. The Fl…

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Opinion of the Court
HENDRY, Judge.

HENDRY, Judge.

This is an appeal by the defendant below from a final judgment declaring the plaintiff, Aaron Bryant, to be eligible to participate in interscholastic athletics as a 'basketball player at Miami Jackson Senior High School during the 1974-75 school year. The trial court also enjoined the defendant from prohibiting the plaintiff from participation in athletics during the 1974-75 school year on the basis of the defendant’s so-called four-year eligibility rule as provided in Article 20, Paragraph 5-1 of the defendant’s bylaws.

The plaintiff’s main contention before the trial court was that he qualifies as a hardship case and therefore the four-year rule should not be invoked in an arbitrary manner to exclude him from participating in basketball during his senior year. The court found that interscholastic basketball is the only sport in which the plaintiff participates and “it is an important and vital part of his life providing an impetus to his general scholastic and social development and rehabilitation from his prior problems as a juvenile delinquent. It has resulted in the improvement of his grades, attitude, self-confidence, discipline and maturity.”

Defendant raises four points seeking to reverse the order appealed. We have carefully considered each point in light of the record, briefs, and arguments of counsel, and have concluded that no reversible error has been shown.

In our view, the contentions of the appellant were answered squarely by this court’s holding' in Lee v. Florida High School Activities Ass’n, Inc., Fla.App.1974, 291 So. 2d 636.

Further, we do not think the defendant has shown that its initial finding that the plaintiff had not presented an adequate case of undue hardship was either fair or 'supported by competent substantial evidence.

The trial court, which heard sworn testimony, determined that there was no. question of “redshirting” involved in this case, a practice which the four-year rule is designed to prevent.

It is our conclusion that the findings of the court are supported by the record and the law, and accordingly the judgment appealed is affirmed.

Affirmed.


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Citator

Cited By

  • Fla. High Sch. Activities Ass'n, Inc. v. Bradshaw, 369 So. 2d 398 (Fla. 2d DCA 1979)
    …the circumstances of those cases, to injunctive relief against the Association on due process grounds. Lee v. Florida High School Activities Association, Inc., 291 So. 2d 636 (Fla. 3d DCA 1974); Florida High School Activities Association v. Bryant, 313 So. 2d 57 (Fla. 3d DCA 1975). That is not the case here; the Association’s waiver of the residence requirement as to Christopher on grounds of hardship made him eligible to participate in future games. Because of the parties’ treatment of the issues in their…
  • The Fla. High Sch. Activities Ass'n, Inc. v. Thomas, 409 So. 2d 245 (Fla. 3d DCA 1982)
    …ternal affairs of a voluntary association. We affirm. We dispose of the second point first. It has heretofore been held in Florida that the FHSAA partakes of a public or quasi-public body. Florida High School Activities Association, Inc. v. Bryant, 313 So. 2d 57 (Fla. 3d DCA 1975); Lee v. Florida High School Activities Association, Inc., 291 So. 2d 636 (Fla. 3d DCA 1974); Sullivan v. Florida High School Activities Association, 38 Fla. Supp. 18 (Cir.Ct.1972). This is particularly true when if you do not belo…
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