Limiting ADA Waivers of High School Sports Eligibility: But-For Causation and Fundamental Alteration in Doe v. Rhode Island Interscholastic League

Introduction

The First Circuit’s decision in Doe v. Rhode Island Interscholastic League (2025) clarifies two critical limits on Americans with Disabilities Act (ADA) accommodation claims in interscholastic athletics: the requirement of “but-for” causation under Titles II and III, and the defense of “fundamental alteration” to a sports program. The dispute arose after John Doe, a high-school athlete with diagnosed psychological and learning disabilities, repeated ninth grade twice (once due to COVID-19 disruptions and once by parental choice) and sought an eight-semester waiver from the League’s eligibility rule so he could play in what would be his fifth year of high school. The League refused, Doe obtained a district-court injunction, and the First Circuit vacated that relief for failure on the merits.

Key issues:

Whether Doe’s disability was the but-for cause of his ineligibility under the eight-semester rule.
Whether waiving the eight-semester eligibility limit would constitute a “fundamental alteration” of the League’s athletics program.
The interplay of ADA Titles II (public entity) and III (public accommodation) in high school sports governance.

Parties:

Plaintiffs/Appellees: James and Jane Doe, on behalf of their son, John Doe.
Defendant/Appellant: Rhode Island Interscholastic League (the “League”).

Summary of the Judgment

The First Circuit vacated the district court’s permanent injunction that had compelled the League to waive its eight-semester rule for Doe. The appellate court held:

No but-for causation: Doe’s disability did not cause his ineligibility under the eight-semester rule. His decision to reclassify and repeat ninth grade — the critical factor triggering a fifth year of eligibility — was unrelated to his disability and thus not a necessary “but-for” cause of the League’s enforcement of the rule against him.
Fundamental alteration: Waiving the eight-semester limit for Doe would “fundamentally alter” the League’s program by upsetting competitive parity, displacing younger athletes, and defeating the League’s core mission of “promoting even competition and maximum participation.”
Because Doe failed both the causation and fundamental-alteration prongs of a reasonable-accommodation claim, his ADA claims under Titles II and III could not succeed, and the injunction was improperly granted.

Analysis

Precedents Cited

Bostock v. Clayton County (2020): Reaffirmed the “but-for” causation test—an event is a but-for cause only if removing it prevents the outcome entirely.
McPherson v. Michigan High School Athletic Association (6th Cir. 1997): Held that an eight-semester rule is essential to statewide athletics administration and waiver would fundamentally alter the program.
Sandison v. Michigan High School Athletic Association (6th Cir. 1995): Upheld age limits in high school sports as essential to competitive fairness.
PGA Tour, Inc. v. Martin (2001): Established that accommodations are unreasonable if they fundamentally alter a sport’s character or give an undue competitive advantage.
Dudley v. Hannaford Bros. Co. (1st Cir. 2003): Applied “but-for” causation for ADA Title III reasonable-accommodation claims.

Legal Reasoning

The court’s reasoning proceeded in two steps:

Causation under Titles II and III: Both Titles require that a plaintiff’s disability be the but-for cause of the challenged exclusion. The panel applied the Supreme Court’s teaching in Bostock, determining that Doe’s disability was not a necessary step in the sequence that led to his ineligibility—his voluntary academic reclassification, not his impairments, fixed the semester count.
Fundamental alteration defense: Even if causation had been established, the League demonstrated that waiving its eight-semester rule would undermine the very objectives of its governance model—ensuring fairness, broad participation, and safety by limiting each student to eight semesters of high school sports. Drawing on Martin and McPherson, the court found this rule essential and the requested exception too disruptive to allow.

Impact

This decision has significant implications for future ADA claims in scholastic athletics and beyond:

It cements the “but-for” causation standard in ADA accommodation suits, narrowing plaintiffs’ ability to seek relief where non-disability factors produce the challenged outcome.
It reinforces the availability of the “fundamental alteration” defense to preserve core eligibility rules in sports leagues, academic programs, and comparable institutions.
It signals deference to state and local associations in structuring uniform, semester- or age-based eligibility requirements, provided those rules are neutrally applied.
It may deter attempts by disabled individuals to obtain special extensions of time-based program benefits where delays or reclassifications stem from personal or administrative choices.

Complex Concepts Simplified

But-For Causation: To win an ADA claim, a plaintiff must show that “but for” his disability, the harmful action would not have occurred. If the same result would happen without the disability, there is no legal “cause.”
Fundamental Alteration: Programs need not provide accommodations that would destroy their basic structure or objectives. In sports, an eligibility rule is “fundamental” if removing it unfairly skews competition or displaces other participants.
Eight-Semester Rule: A common high-school athletics rule limiting participation to eight consecutive semesters after ninth grade, designed to balance team rosters and promote fair play across member schools.
Titles II & III of the ADA: Title II applies to public entities (e.g., state-chartered leagues); Title III applies to places of public accommodation (e.g., private schools hosting league sports). Both forbid discrimination and require reasonable accommodations, subject to defenses like undue burden or fundamental alteration.

Conclusion

Doe v. Rhode Island Interscholastic League reaffirms that ADA accommodation claims must clear a dual hurdle: showing a necessary “but-for” link between the disability and the challenged rule, and demonstrating that the requested relief will not fundamentally alter the program’s essential character. High-school athletic associations nationwide can rely on this precedent to uphold uniform eligibility limits that serve core educational and competitive values. Students and families, in turn, must recognize that the ADA does not entitle them to unlimited extensions of time-based academic or extracurricular benefits when reclassification or delayed progress arises from choices or circumstances independent of their disabilities.