National Collegiate Rugby Inc. v. McGregor
1:25-cv-00269
| W.D. Tex. | Jun 27, 2025Background
- National Collegiate Rugby Inc. (NCR) is an independent organization that provides college rugby services for over 630 schools and 18,000 participants across the U.S.
- USA Rugby is the designated national governing body (NGB) for rugby under the Ted Stevens Olympic and Amateur Sports Act (the Act) and has experienced recent financial and operational difficulties.
- NCR alleges USA Rugby and its official Jamie McGregor disseminated false information to referees and third parties—claiming NCR events were “unsanctioned” and threatening sanctions against referees participating in NCR events.
- NCR sued for violations of the Act, tortious interference, defamation, fraud by omission, and violation of the Deceptive Trade Practices Act.
- NCR moved for partial summary judgment; Defendants moved to stay the case and compel arbitration under the Act.
- The magistrate judge must determine whether NCR’s claims must go to arbitration, are preempted, or state a valid federal claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Act creates a private federal cause of action | NCR asserts the Act does not mandate arbitration and does not preempt its state-law claims | USA Rugby argues NCR’s claims are preempted by the Act and must proceed under the Act’s dispute resolution/arbitration procedures | Act does not provide a private right of action; NCR must use Act’s procedures |
| Whether state-law claims are preempted by the Act | NCR argues its state-law claims are outside the Act and are not preempted | USA Rugby argues NCR’s state-law claims all concern authority under the Act and are thus preempted | State-law claims are preempted if they center on NGB authority under the Act |
| Whether Act’s arbitration procedures are mandatory or permissive | NCR argues arbitration is not required and only applies to Olympic eligibility disputes | USA Rugby asserts the Act establishes mandatory administrative and arbitration processes for all disputes involving participation/opportunity | Arbitration processes are mandatory for disputes concerning NGB authority/opportunity to participate |
| Whether court can stay the case and compel arbitration | NCR contends the Act doesn’t permit court-ordered arbitration in these circumstances | USA Rugby seeks to stay and compel arbitration | Court dismisses action (rather than stay and compel), holding all claims must follow Act’s remedies |
Key Cases Cited
- Eleven Line, Inc. v. N. Texas State Soccer Ass'n, Inc., 213 F.3d 198 (5th Cir. 2000) (explaining the vertical structure and authority under the Ted Stevens Act)
- Slaney v. Int’l Amateur Athletic Fed’n, 244 F.3d 580 (7th Cir. 2001) (finding the Act preempts state law claims that depend on NGB authority under the Act)
- Lee v. U.S. Taekwondo Union, 331 F. Supp. 2d 1252 (D. Haw. 2004) (holding Act preempts state law challenges that rely on NGB authority)