Ozell Jones v. Wichita State University and National Collegiate Athletic Association

698 F.2d 1082, 1983 U.S. App. LEXIS 31157, 9 Educ. L. Rep. 63
CourtCourt of Appeals for the Tenth Circuit
DecidedJanuary 24, 1983
Docket81-1337
StatusPublished
Cited by11 cases

This text of 698 F.2d 1082 (Ozell Jones v. Wichita State University and National Collegiate Athletic Association) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ozell Jones v. Wichita State University and National Collegiate Athletic Association, 698 F.2d 1082, 1983 U.S. App. LEXIS 31157, 9 Educ. L. Rep. 63 (10th Cir. 1983).

Opinions

BARRETT, Circuit Judge.

Plaintiff-appellant Ozell Jones (Jones) appeals from the district court’s denial of a motion for a preliminary injunction. Jones had sued the defendants, the National Collegiate Athletic Association (NCAA), Wichita State University (WSU) and the Missouri Valley Conference1, seeking to enjoin them from declaring him ineligible to practice and compete as a member of the Wichita State University varsity basketball team. Jones sued under 42 U.S.C.A. § 1983, with jurisdiction based on 28 U.S.C.A. § 1343(3).2 A recital of the facts leading to the denial of the motion is necessary to facilitate our review.

NCAA is a voluntary unincorporated association which regulates much of the nation’s intercollegiate athletics. It consists of approximately 870 four year colleges and universities located throughout the United States. The general policies of the NCAA are established by its members at annual conventions, and carried out by its council of twenty-two members, who are elected by the membership at the annual conventions. NCAA’s'purposes include: encouraging its members to adopt eligibility rules to comply with satisfactory standards of scholarship, sportsmanship and amateurism; supervising the conduct of, and establishing eligibility standards for, regional and national athletic events; and legislating, through bylaws or resolution of a convention, upon any subject of general concern to the members in the administration of intercollegiate athletics. [R., Vol. I, p. 20].

Jones is a student athlete who enrolled as a freshman at WSU, an NCAA member, in the fall of 1979. He had been awarded a basketball scholarship. Prior to his enrollment at WSU, Jones graduated from Polytechnic High School in Long Beach, California, at the end of the 1978-79 school year. Upon graduation, his high school grade point average (GPA), including physical education grades, was 2.38. Without the physical education grades, Jones’s GPA was 1.59.

NCAA has a 2.000 eligibility rule for freshmen student athletes which is set forth in its bylaws.3 The rule requires high school students to graduate with a 2.000 or better GPA to be eligible for athletic finan[1084]*1084cial aid and competition for a Division I school in their freshman year. The 2.000 rule is augmented by NCAA case interpretations Nos. 329 and 330.4 These interpretations provide that the GPA, for purposes of the 2.000 rule, is to be calculated by the high school for the student athlete in the same manner as the GPA would be calculated for any student at the high school. That is, the NCAA leaves it up to the high school to calculate the student athlete’s GPA, including or excluding whatever courses the high school deems appropriate in calculating the GPAs of the entire student body. Some high schools include physical education courses in the calculation of the GPA, while some do not. Similarly, some schools also exclude from the calculation of the GPA grades received in courses such as ROTC, student aide, military science, and the like. Case interpretations must be followed by NCAA member institutions. Failure to do so subjects a member to NCAA sanctions.

Toward the end of the basketball season in Jones’s sophomore year (late February, 1981) the Commissioner of the Missouri Valley Conference, of which WSU is a member, learned that Jones’ participation on the WSU basketball team during his freshman [1085]*1085year may have been in violation of the 2.000 rule as supplemented by the case interpretations. The high school from which Jones graduated did not normally include physical education grades in calculating GPAs for all students. For purposes of NCAA eligibility under the 2.000 rule, then, Jones had less than the required GPA to compete in intercollegiate athletics his freshman year.5

On March 2, 1981, WSU declared Jones ineligible to compete on its varsity basketball team. Under NCAA case interpretation No. 334,6 since Jones had played one year while he was ineligible, he would be ineligible to compete in interscholastic athletics for an entire year, i.e., he would be required to “sit out” one year. Further, if Jones remained at WSU, he would entirely lose one of his remaining two years of eligibility. If Jones transferred to another university, however, he would be eligible to compete for two more years, after sitting out for one year.

After WSU declared Jones ineligible, it exercised its right and appealed its decision to the NCAA. The expedited appeal was denied after a hearing on March 3, 1981. Jones immediately filed suit, claiming that although the NCAA 2.000 rule was valid, case interpretations Nos. 329 and 330 denied him equal protection under the law as guaranteed by the Fourteenth Amendment to the United States Constitution. The trial court granted a temporary restraining order which allowed Jones to continue competing with WSU’s basketball team until his motion for a preliminary injunction was heard on March 12, 1981.

After a full hearing on the motion, the trial court ruled that a federal question existed within the purview of the Fourteenth Amendment; that a rational relationship existed between the rule and its permissible objectives; and that, therefore, Jones had not demonstrated a likelihood of success on the merits. The trial court consequently denied the motion for a preliminary injunction.

I.

Jones contends that the trial court did not err in finding that he presented a substantial federal question, thereby vesting the court jurisdiction to hear his claim.7 In light of the clear precedent in this circuit regarding suits by student athletes, we disagree.

In Wiley v. NCAA, 612 F.2d 473 (10th Cir.1979), cert. denied, 446 U.S. 943, 100 S.Ct. 2168, 64 L.Ed.2d 798 (1980), we stated, “[tjhis court has consistently found that, unless clearly defined constitutional principles are at issue, the suits of student-athletes displeased with high school athletic associations or NCAA rules do not present substantial federal questions.” Id. at 477.

[1086]*1086Wiley followed a line of Tenth Circuit opinions which entertained similar issues and reached the same conclusions. See Colorado Seminary v. NCAA, 570 F.2d 320 (10th Cir.1978); Albach v. Odle, 531 F.2d 983 (10th Cir.1976); Oklahoma High School Athletic Association v. Bray, 321 F.2d 269 (10th Cir.1963). Jones seeks to distinguish Wiley because of our statement that “the case does not implicate the right to a college education, or even to participate in intercollegiate athletics.” Wiley, 612 F.2d at 476. (Wiley had been declared ineligible due to financial aid in excess of NCAA regulations, but continued participating in intercollegiate athletics until his graduation under protective court order.)

While it is true that in Wiley the student had already graduated, and only his records and awards were at stake, we are of the view that the principle still applies. As in the present case, Wiley involved an NCAA regulation which made the student-athlete ineligible to participate in intercollegiate athletics.

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Bluebook (online)
698 F.2d 1082, 1983 U.S. App. LEXIS 31157, 9 Educ. L. Rep. 63, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ozell-jones-v-wichita-state-university-and-national-collegiate-athletic-ca10-1983.