Scott v. Oklahoma Secondary School Activities Ass'n
2013 OK 84
| Okla. | 2013Background
- Scott, Sequoyah High School quarterback, sought a permanent injunction against OSSAA after OSSAA deemed him ineligible for attending camps funded by Sequoyah; district court denied, Scott appealed.
- OSSAA investigated Camp/tuition payments from 2009–2012; November 8, 2012 OSSAA forfeited wins, barred playoffs, and suspended the head coach; later sanctions included monetary penalties.
- Scott sought injunctive relief to finish the 2012 season; OSSAA Board's actions were challenged as arbitrary and capricious, with emphasis on retroactive policy application and pre-notice deficiencies.
- Court held the district court erred by deferring excessively to OSSAA under Morgan; OSSAA is not a traditional voluntary association and should be reviewed more like an agency under APA § 322; however, ruling applied broadly under any standard.
- Court found mootness exceptions applicable and reversed the district court; monetary penalties related to the inquiry were reversed; decision extends to future OSSAA actions and cases with similar circumstances.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| What standard applies to OSSAA decisions? | Scott: Morgan deferential standard improper. | OSSAA: Morgan deference appropriate. | APA-style review required; district court erred. |
| Was OSSAA's action arbitrary and capricious under the applicable standard? | Scott: OSSAA acted arbitrarily and capriciously in applying rules. | OSSAA: decisions based on policy and evidence. | Yes, OSSAA acted arbitrarily and capriciously. |
| Was OSSAA's retroactive policy application lawful? | Scott: retroactive D.2 application improper. | OSSAA: policy interpretation valid. | Retroactive application was arbitrary and capricious. |
| Do mootness exceptions permit review? | Scott: controversy capable of repetition and public interest. | OSSAA: moot after season; no live issue. | Exceptions satisfied; appeal proper for review. |
| Are penalties beyond Rule violations properly authorized? | Scott: penalties (e.g., reimbursement of attorney fees) unsupported. | OSSAA: penalties within authority. | Monetary penalties reversed as arbitrary and capricious. |
Key Cases Cited
- Morgan v. Oklahoma Secondary School Activities Ass'n, 2009 OK 21 (Okla. 2009) (deference to OSSAA; limited injunctive relief in similar contexts)
- Christian Heritage Academy v. Oklahoma Secondary School Activities Association, 488 F.3d 1025 (10th Cir. 2007) (OSSAA state actor; standard of review discussions cited)
- Wright City Public Schools v. Oklahoma Secondary School Activities Ass'n, 2013 OK 35 (Okla. 2013) (concerns about executive director power; scrutiny of OSSAA actions)
- Bd. of Regents of University of Oklahoma v. National Collegiate Athletic Ass'n, 561 P.2d 499 (Okla. 1977) (courts may scrutinize voluntary associations when public welfare requires)