Indiana High School Athletic Ass'n v. Martin

731 N.E.2d 2
CourtIndiana Court of Appeals
DecidedJune 14, 2000
DocketNo. 02A03-9912-CV-460
StatusPublished
Cited by1 cases

This text of 731 N.E.2d 2 (Indiana High School Athletic Ass'n v. Martin) is published on Counsel Stack Legal Research, covering Indiana Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Indiana High School Athletic Ass'n v. Martin, 731 N.E.2d 2 (Ind. Ct. App. 2000).

Opinion

OPINION

ROBB, Judge

Case Summary

Indiana High School Athletic Association (“IHSAA”) appeals the trial court’s grant of injunctive relief for Jessah Martin. We affirm. '

Issue

IHSAA raises one issue for our review which we restate as whether the trial court [4]*4properly granted Martin’s motion for preL liminary injunction.

Facts and Procedural 'History1

Martin attended Bellmont High School through the 1998-99 school year-and competed in athletics there. After having personal problems with her family, Martin moved out of her home during the summer of 1999 and into the home of one of her former assistant basketball coaches, Harry Miller, and his family. The Miller home is also located in the Bellmont school district. However, because of problems that Martin had experienced at Bellmont, she chose to switch schools contemporaneously with her move and transferred to Bishop Luers High School.

Martin, wishing to continue to play varsity basketball at Bishop Luers, proceeded with the paperwork explaining her transfer. Administrators at both Bellmont and Bishop Luers provided information for the IHSAA Athletic Transfer Report which indicated that Martin was transferring without a change of residence by her parents but was requesting immediate athletic eligibility because she was emancipated.2 Bishop Luers provided that the reason for the transfer was personal concerns, including her mother’s employment within the Bellmont school district, and recommended that Martin be declared immediately eligible according to Rule 19-6.1, titled Transfer Eligibility Without Change of Residence by Parent(s)/Guardian(s), Immediate Eligibility. However, Bellmont indicated that Martin had moved out of her house unannounced, that Martin’s reason for leaving Bellmont was unknown, and suggested that an additional investigation should be made.

IHSAA granted Martin limited, or junior varsity, eligibility. Martin requested a hearing wherein the IHSAA committee heard from Martin, Miller, and another of Martin’s previous assistant coaches from Bellmont, Robert Hacker. Martin also provided the .committee with letters ex-, plaining the situation that she was in at Bellmont, as well as describing her personal problems. At the hearing, it was explained that Martin did not fit IHSAA’s definition of emancipation because she did not live on her own and was not self-supportive. Thus, Martin sought a hardship exception to the transfer rule so that she would be allowed to play varsity sports.3 However, IHSAA determined that under the IHSAA Eligibility Rules, Martin qualified for only limited eligibility for a 365 day period commencing on the date of her last participation in sports at Bellmont, after which she would have gen[5]*5eral eligibility. , Further, THSAA noted in its ruling that it had considered Martin’s hardship request, but had determined that she failed to demonstrate she was entitled to an exception under the hardship rule.

Martin then instituted a lawsuit and filed a motion seeking a preliminary injunction and declaratory judgment to permanently enjoin the enforcement of IHSAA’s limited eligibility ruling. After a hearing, the trial court granted- Martin’s motion and preliminarily enjoined' I-HSAA from enforcing its ruling that Martin had limited eligibility. Thus, the trial court found that Martin was eligible to immediately participate in varsity athletic events at Bishop Luers High School. However, Martin chose not to participate and did not play basketball. IHSAA properly instituted this interlocutory appeal.

Additional facts will be provided as necessary.

Discussion and Decision

I. Mootness

Although not raised by the parties, we initially note that because Martin elected not to participate in basketball and because the basketball season is now oyer, it would appear that the issue of whether or not the preliminary injunction was proper would be moot. However, because, both parties are still involved in litigation4 and the issue of attorneys fees is still viable, this case is not moot and we have jurisdiction to decide this case. See Washington, et al. v. Indiana High School Athletic Ass’n., Inc., et al., 181 F.3d 840, 844 (7 th Cir.1999), cert. denied, — U.S. —, 120 S.Ct. 579, 145 L.Ed.2d 482 (1999) (holding that, although the basketball season was completed, because an actual controversy still existed the court had jurisdiction and review was proper).

II. Standard of Review

Our standard of reviewing a ruling on an injunction is deferential; the grant or denial of an injunction is a discretionary matter for the trial court. Grand Trunk Western R.R. Co. v. Kapitan, 698 N.E.2d 368, 366 (Ind.Ct.App.1998), trans: denied. “We will not interfere with the exercise of that discretion unless' it is' shown that the trial court’s action was arbitrary or constituted a clear abuse of-discretion.” Indiana State Bd. of Pub. Welfare v. Tioga Pines Living Ctr., Inc.; 637 N.E.2d 1306, 1311 (Ind.Ct.App.1994). An abuse of discretion occurs when the trial court’s décision is clearly against the logic and effect of the facts and circumstances or if the trial "court" misinterprets the law. Grand Trunk, 698 N.E.2d at 366. Upon review of the trial court’s action, we will not weigh conflicting evidence. Id. We will only consider the evidence which supports the trial court’s findings, conclusions, and order. Id.

In order to" determine whether the trial court abused its discretion, we first review the trial court’s findings of fact. Tioga Pines, 637 N.E.2d at 1311. We then determine whether the trial court’s findings support the judgment and whether, based on the findings, the conclusions of law and judgment are" clearly erroneous. American Cyanamid Co. v. Stephen, 623 N.E.2d 1065, 1070 (Ind.Ct.App.1993). “Whether such findings of fact’ áre adequate depends upon whether they are sufficient to disclose a valid basis under the issues for the legal result reached in the judgment and whether they are sup.ported by evidence of probative value. Such findings may not be set aside unless they are clearly erroneous.” Tioga Pines, 637 N.E.2d at 1311 (quoting College Life Ins. Co. of Am. v. Austin, 466 N.E.2d 738, 742 (Ind.Ct.App.1984)).

[6]*6III. Grant of Preliminary Injunctive Relief

A. Trial Court’s Standard of Review of IHSAA Rulings

“[A]s a matter of state common law, the [trial] courts of Indiana have jurisdiction to review challenges to IHSAA rules and enforcement decisions applicable to a particular student.” Indiana High School Athletic Ass’n, Inc. v. Carlberg,

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