Age Restrictions in High School Athletics and Disability Law: Sandison & Stanley v. MHSAA

Introduction

Sandison & Stanley v. Michigan High School Athletic Association (MHSAA) is a pivotal case adjudicated by the United States Court of Appeals for the Sixth Circuit on September 12, 1995. The plaintiffs, Ronald G. Sandison and Craig M. Stanley, both high school graduates with learning disabilities, challenged the MHSAA's regulation that prohibits students who turn nineteen by September 1st of the school year from participating in interscholastic sports. This case delves into the intersection of disability law and athletic eligibility criteria, raising significant questions about age-based restrictions and discrimination under the Rehabilitation Act of 1973 and the Americans with Disabilities Act (ADA).

Summary of the Judgment

Sandison and Stanley, both of whom were nineteen years old at the commencement of their senior year due to their learning disabilities, sought to participate in high school sports teams. The MHSAA's Regulation I § 2 explicitly barred students over nineteen from competing, with no provision for waivers. The plaintiffs filed a lawsuit alleging discrimination under the Rehabilitation Act and the ADA. The district court granted a preliminary injunction allowing them to participate and restraining the MHSAA from penalizing the schools for this participation. However, upon appeal, the Sixth Circuit dismissed part of the injunction as moot and reversed the portion preventing the MHSAA from sanctioning the schools, holding that the age restriction did not constitute discrimination "solely by reason of" disability.

Analysis

Precedents Cited

The judgment extensively references key precedents to interpret the scope of disability discrimination:

SOUTHEASTERN COMMUNITY COLLEGE v. DAVIS (1979): Established that section 504 of the Rehabilitation Act requires "evenhanded treatment of qualified handicapped persons" without mandating affirmative action.
Wimberly v. Labor and Industrial Relations Commission of Missouri (1987): Interpreted "solely on the basis of" in the context of pregnancy discrimination, emphasizing neutral rules' non-discriminatory application.
DOHERTY v. SOUTHERN COLLEGE OF OPTOMETRY (1988): Clarified the elements of a section 504 claim, highlighting the necessity of proving "otherwise qualified" status and the feasibility of reasonable accommodations.
Pottgen v. Missouri High School Activities Association (1994): Affirmed that age restrictions in high school athletics are essential eligibility requirements and not subject to reasonable accommodation under section 504.
ALEXANDER v. CHOATE (1985): Discussed the potential for disparate impact claims under section 504, though the court refrained from extending its ruling to broader contexts.

Legal Reasoning

The court's reasoning centered on the interpretation of whether the MHSAA's age restriction constituted discrimination "solely by reason of" disability:

Neutrality of the Rule: The age restriction was deemed a neutral rule not specifically targeting disabilities, as it applied equally to both disabled and nondisabled students.
Essential Eligibility Requirement: The court agreed with the district court's assessment that the age limit serves legitimate purposes, including safeguarding athletes from injury and maintaining competitive fairness.
Reasonable Accommodation: Waiving the age restriction was not considered a reasonable accommodation as it would fundamentally alter the nature of the athletic programs and impose undue burdens on the MHSAA.
Mootness Doctrine: The court dismissed the injunction allowing participation as moot since the plaintiffs had graduated, but upheld the reversal preventing the MHSAA from penalizing the schools.

Impact

This judgment has significant implications for the administration of high school athletics and disability law:

Clarification of Disability Discrimination: It reinforces the necessity for plaintiffs to demonstrate that a challenged policy directly and solely disadvantages them due to their disability.
Age Restrictions: Affirms the legitimacy of age-based eligibility criteria in high school sports, provided they serve essential objectives and are applied neutrally.
Accommodation Limitations: Highlights the boundaries of reasonable accommodations, especially when proposed changes would fundamentally alter program structures or impose significant administrative burdens.
Legal Precedent: The case is likely to be cited in future disputes involving eligibility criteria intersecting with disability rights, offering a framework for analyzing similar claims.

Complex Concepts Simplified

"Solely by Reason of" Disability

This legal phrase requires that discrimination be directly linked to an individual's disability, without interference from other factors. In this case, the court determined that the age restriction was based on age alone, not the plaintiffs' disabilities.

Reasonable Accommodation

Under disability law, reasonable accommodation refers to modifications or adjustments that enable a person with a disability to participate fully. The court found that waiving the age limit was not a reasonable accommodation as it would disrupt the fairness and integrity of athletic programs.

Mootness

A legal issue becomes moot when the underlying circumstances change, rendering the dispute irrelevant. The plaintiffs' graduation meant they could no longer participate in the current athletic season, making that aspect of the injunction unnecessary.

Conclusion

The Sandison & Stanley v. MHSAA judgment underscores the delicate balance between upholding disability rights and maintaining fair, essential standards within extracurricular programs. By affirming the legitimacy of age restrictions and delineating the limits of reasonable accommodations, the court provided clarity on how neutral policies intersect with disability protections. This case serves as a cornerstone for educators, athletic associations, and legal professionals navigating the complexities of eligibility criteria and discrimination law, ensuring that while disabilities are rightfully protected, fundamental programmatic standards are preserved.