Wright City Public Schools v. Oklahoma Secondary School Activities Ass'n
2013 OK 35
| Okla. | 2013Background
- Wright City’s varsity baseball team exceeded OSSAA’s 22-game limit by playing two post-season games (Idabel JV and Valliant) after district/regional wins, which coach treated as practice/scrimmage and believed the limit applied only to regular season.
- OSSAA Executive Director imposed a forfeiture of Wright City’s next state-tournament game and a future-season game limit, citing lack of a specific penalty for this violation and precedent from other cases.
- Wright City filed for injunctive relief in district court on May 1, 2018; the court granted an ex parte temporary restraining order to allow Wright City to participate in the May 2 tournament games.
- At the May 3, 2018 hearing, the Executive Director testified about Guthrie and Sand Springs precedents and that penalties were discretionary where no specific rule existed.
- The majority held the Executive Director’s actions were arbitrary and unlawful because there was no explicit penalty for the violation and due-process procedures were not followed, including treatment of reconsideration requests as meetings or appeals.
- The court dissolved the district court’s temporary injunction and remanded to stay proceedings until Wright City can challenge the rule violation before the OSSAA Board of Directors pursuant to OSSAA’s Constitution.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the trial court abuse its discretion by issuing a temporary injunction against OSSAA? | Wright City argues injunction was warranted to prevent irreparable harm while due process is pursued. | OSSAA argues no abuse since prerequisites for an injunction were not properly met and penalties are discretionary. | Yes; injunction dissolved and remanded. |
| Was the forfeiture penalty for Wright City's 22-game violation arbitrary or beyond applicable rules? | Wright City contends penalty was outside the established penalties and arbitrary given lack of specific rule. | OSSAA contends penalties may be fashioned based on precedent where no specific penalty exists. | Yes; penalty deemed arbitrary and not authorized by policy. |
| Did OSSAA violate due process by not following Board procedures before imposing penalties? | Wright City asserts due process rights to meet with investigator and appeal were not fulfilled. | OSSAA contends procedures exist but Wright City did not properly invoke them in this proceeding. | Yes; due process procedures were not properly followed; Board decision required. |
Key Cases Cited
- Brown v. Oklahoma Secondary School Activities Association, 125 P.3d 1219 (2005 OK 88) (courts will intervene to ensure fair, good-faith enforcement of association rules)
- Mahan v. Agee, 652 P.2d 765 (1982 OK 116) (due process and non-arbitrary enforcement context in OSSAA-like actions)
- Midget v. Oklahoma Secondary School Activities Association, 505 P.2d 175 (1972 OK 154) ( OSSAA procedures and limitations in enforcement actions)
- Board of Regents of the University of Oklahoma v. National Collegiate Athletic Association, 561 P.2d 499 (1977 OK 17) (principles governing regulation of intercollegiate conduct and due process)
- Oklahoma Secondary School Activities Association v. Midget, 505 P.2d 175 (1972 OK 154) (due process and administrative review in OSSAA matters)
- Morgan v. Oklahoma Secondary School Activities Association, 207 P.3d 362 (2009 OK 21) (courts may enforce proceedings to be conducted under constitution, rules, and policies)