Mississippi High School Activities Association, Inc. v. Richard Rusty Trail
2015 Miss. LEXIS 229
| Miss. | 2015Background
- DeSoto County School District contracts with MHSAA, delegating eligibility determinations to MHSAA under its handbook and rules.
- In 2013, RT, a high school quarterback, transfers from Wynne, Arkansas to Olive Branch High School; MHSAA allows spring eligibility but conditions future eligibility on a bona fide move.
- MHSAA later determines RT is ineligible for football, asserting the Trails did not make a bona fide move to the district.
- The Trails obtain a TRO and preliminary injunction in chancery court; MHSAA seeks dismissal under Rule 12(b)(6) for lack of standing and prematurity.
- The chancery court initially dismisses, but RT is later found to have standing as a direct beneficiary of hardship provisions in the contract; the case is appealed to resolve standing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether RT has standing to challenge MHSAA eligibility decisions. | Trails: RT is a third-party beneficiary of the contract. | MHSAA: RT lacks standing; no enforceable rights. | Yes; RT is an intended third-party beneficiary with standing. |
| Whether student-athletes have a cognizable legal right to participate in athletics. | Students have a right to participate due to contract-like framework. | Participation is a privilege, not a protected right. | Students are intended beneficiaries; standing exists. |
| Whether MHSAA bylaws confer enforceable rights on students against MHSAA. | Bylaws create rights benefiting students. | Bylaws govern schools, not enforceable by students. | Bylaws confer rights to students; standing established. |
Key Cases Cited
- Miss. High School Activities Ass’n v. Farris, 501 So.2d 393 (Miss. 1987) (whether students are intended beneficiaries under MHSAA handbook)
- NCAA v. Gillard, 352 So.2d 1072 (Miss. 1977) (participation is a privilege governed by participation standards)
- Scott v. Kilpatrick, 286 Ala. 129 (Ala. 1970) (internal association rules should not be interfered with by courts)
- Miss. High School Activities Ass’n v. Coleman, 631 So.2d 768 (Miss. 1994) (anti-recruitment regulation rationally related to legitimate interest)
- Sideboard, 133 So.3d 671 (Miss. 1931) (ancillary authority on third-party beneficiary status)