Mississippi High School Activities Ass'n v. Hattiesburg High School
2015 Miss. LEXIS 520
| Miss. | 2015Background
- Tiaria Griffin (a high‑school basketball player) and her brother transferred to Hattiesburg High School (HHS); MHSAA declared them ineligible for 2011–2012 athletics and assessed penalties against HHS for fielding Tiaria.
- Initial TROs and preliminary injunctions issued in chancery court; case was briefly removed to federal court and then remanded; HHS intervened and proceeded as the sole plaintiff after this Court dismissed the student plaintiffs for failure to state a cause of action.
- HHS sued MHSAA seeking injunctive relief, alleging MHSAA acted arbitrarily and failed to follow its own rules (residency, special‑inducement, and good‑standing rules); chancery court held a five‑day trial, vacated penalties and granted relief.
- MHSAA appealed, arguing it is a state‑delegated entity entitled to administrative (substantial‑evidence) review and that chancery court improperly conducted de novo review; the Supreme Court questioned whether MHSAA is an administrative body and whether chancery has jurisdiction to review a private association.
- The Supreme Court held MHSAA is a private voluntary non‑profit (not a state agency), there is no automatic chancery appeal from its decisions, and a plaintiff must plead a cognizable legal or equitable claim (contract, tort, etc.) to obtain injunctive relief; HHS’s complaint failed to do so and chancery decisions were vacated.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is MHSAA a state administrative agency entitled to agency‑style appellate deference? | HHS: MHSAA is private; not entitled to agency status. | MHSAA: member school boards delegated regulatory authority; MHSAA functions like an agency and merits deferential review. | MHSAA is a private voluntary association, not a state agency; no automatic right to agency‑style review. |
| Does chancery court have jurisdiction to review MHSAA decisions absent statutory appeal? | HHS: chancery can grant equitable relief when no adequate remedy at law; court can enjoin private associations when a cognizable claim exists. | MHSAA: no right of appeal from private org; review limited and should be deferential if at all. | No inherent chancery right to appeal MHSAA decisions; review available only when plaintiff pleads a cognizable legal/equitable claim. |
| Did HHS plead a legally cognizable claim enabling injunctive relief? | HHS: alleged arbitrary and capricious action and failure to follow MHSAA rules (effectively a contract/breach). | MHSAA: plaintiffs failed to plead breach of contract, tort, or other legal duty—mere assertion of arbitrariness is insufficient. | HHS’s complaint did not plead breach of contract, tort, due process, or other cognizable cause; mere allegations of arbitrariness are inadequate. |
| May courts review private association decisions for arbitrariness and, if so, was MHSAA’s action reviewable here? | (Dissent) Private associations’ actions are reviewable for arbitrariness; HHS adequately alleged such a claim and evidence shows MHSAA acted arbitrarily. | (Majority) While courts can review when a cognizable claim exists, HHS did not allege such a claim here. | Majority: review permitted only where complaint states a cognizable legal claim; vacated chancery judgment for lack of properly pleaded claim. (Dissent would have reviewed merits and upheld chancery relief.) |
Key Cases Cited
- Prisock v. Perkins, 735 So.2d 440 (Miss. 1999) (chancery review of state board/agency decisions when no statutory appeal exists and no adequate remedy at law)
- Owens Corning v. Mississippi Ins. Guar. Assoc., 947 So.2d 944 (Miss. 2007) (private organization not entitled to administrative‑agency deference)
- Mississippi Windstorm Underwriting Ass’n v. Union Fire Ins. Co., 86 So.3d 216 (Miss. 2012) (private association not an administrative agency; no deference)
- Mississippi High School Athletic Activities Ass’n v. Coleman, 631 So.2d 768 (Miss. 1994) (MHSAA treated as state action for constitutional analysis but not as a state agency for appeal/deference)
- In re Bell, 962 So.2d 537 (Miss. 2007) (injunctive relief in chancery must be predicated on a cognizable legal or equitable claim)
- Lowery v. Int’l Bhd. of Boilermakers, 130 So.2d 831 (Miss. 1961) (private association rules constitute contract among members; courts review for fraud, lack of jurisdiction, or arbitrariness)
- Multiple Listing Serv. of Jackson, Inc. v. Century 21 Cantrell Real Estate, Inc., 390 So.2d 982 (Miss. 1980) (judicial review of private association disciplinary actions limited and exhaustion of internal remedies required)
- Mississippi High Sch. Activities Ass’n v. Trail, 163 So.3d 274 (Miss. 2015) (students have standing as third‑party beneficiaries to challenge MHSAA eligibility rulings)
- Elec. Data Sys. Corp. v. Miss. Div. of Medicaid, 853 So.2d 1192 (Miss. 2003) (administrative‑law standards: review for substantial evidence, arbitrary and capricious, ultra vires, or constitutional/statutory violation)