Indiana High School Athletic Ass'n v. Watson, 938 N.E.2d 672

Jasmine Watson transferred from Elkhart Memorial to South Bend Washington to play basketball and track; IHSAA deemed her ineligible for primarily athletic reasons.
Watsons faced financial hardship including foreclosure; Valerie Watson moved the family to South Bend for support and proximity to extended family.
Witnesses testified Scott, a Washington coach, recruited Jasmine; Memorial alleged undue influence and transfer for athletic reasons, which IHSAA found under Rules 20-1 and 19-4.
Memorial refused to approve the transfer; IHSAA ruled Jasmine ineligible; the Watsons sought judicial review and preliminarily injunctive relief.
Trial court enjoined enforcement; Court of Appeals affirmed; the Supreme Court reversed, holding the IHSAA’s findings were not arbitrary and capricious, based on substantial evidence.
Post-decision, legislature amended review procedures to require an independent case review panel for future cases; Jasmine had already graduated, affecting mootness considerations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the IHSAA decision arbitrary and capricious?	Watsons contend the record shows no primarily athletic motive.	IHSAA argues substantial evidence supports transfer for primarily athletic reasons.	Not arbitrary or capricious; substantial evidence supports the decision.
Did undue influence by Memorial coaches affect Jasmine's transfer?	Undue influence did not drive Jasmine’s move; evidence insufficient.	IHSAA properly weighed evidence showing undue influence under Rule 20-1.	Undue influence found; supports transfer ruling.
Did the trial court improperly reweigh the evidence?	Court should not substitute its judgment for the IHSAA.	Court properly reviewed the record under appropriate standard.	Trial court improperly reweighed evidence; appellate standard applied correctly.
Should the Court of Appeals’ framework have controlled review here?	Appeals court should defer to IHSAA findings absent clear error.	Administrative final say is consistent with substantial evidence standard; deference appropriate.	Yes; court correctly applied substantial evidence standard and deferential review.

Carlberg v. Indiana High School Athletic Ass'n, 694 N.E.2d 222 (Ind. 1997) (arbitrary and capricious standard for IHSAA decisions; substantial evidence required)
Reyes v. Indiana High School Athletic Ass'n, 659 N.E.2d 158 (Ind. Ct. App. 1995) (administrative review analogized to agency review; substantial evidence standard)
C.T.S. Corp. v. Schoulton, 383 N.E.2d 293 (Ind. 1978) (agency decisions may rely on hearsay where properly weighed)
Crane v. Indiana High Sch. Athletic Ass'n, 975 F.2d 1315 (7th Cir. 1992) (challenge to application of rules; consistency of enforcement)
Regester v. Ind. State Bd. of Nursing, 703 N.E.2d 147 (Ind. 1998) (read record in light most favorable to agency; substantial evidence standard)
Midwest Minerals, Inc. v. Bd. of Zoning Appeals of Area Plan Dep't/Comm'n of Vigo County, 880 N.E.2d 1269 (Ind. Ct. App. 2008) (substantial evidence standard applied to administrative rulings)