The Indiana Court of Appeals reversed a preliminary injunction against the Indiana High School Athletic Association in a case involving a fight between Griffith and Hammond High Schools last year that allowed both schools to participate in the IHSAA tournament. The COA said the trial court improperly added its own judgment and remanded the case to the trial court for further proceedings.
During a basketball game on Feb. 7, 2015, students from both schools came on the court during a fight, as well as coaches, parents and fans. The IHSAA called both schools for a meeting the next day and ruled both schools’ teams could not participate in the IHSAA state boys’ basketball tournament and would be on probation for the rest of the season after violating two IHSAA rules and one National Federation of State High School Associations rule.
After appealing to the IHSAA review committee and receiving the same result, Griffith and Hammond appealed to a trial court for judicial review. The trial court issued a preliminary injunction, finding the penalties imposed by the IHSAA were disparate treatment and suggested the IHSAA did not follow its own rules. It cited IHSAA Rule 8-4, which said if a player is involved in any unsportsmanlike conduct for the first time, you lose eligibility for one game, but Hammond and Griffith lost the rest of their seasons. The IHSAA filed an interlocutory appeal.
The COA held the students’ interest in the outcome of the decision is now moot, because the tournament is already over. “The students already participated in the state tournament, and nothing short of time travel can change that fact,” Judge Margret Robb wrote in the court’s opinion.
The schools’ interest is not moot, however, due to records, wins and losses, and history of the school.
The COA did say the trial court erred when it found Griffith and Hammond demonstrated a reasonable likelihood of success on the merits. The COA said because the IHSAA is treated as a voluntary organization, absent illegal actions, courts does not interfere with internal affairs. The IHSAA’s suspension did not go against its own rules, and nothing in its rules requires the IHSAA to give similar punishments for similar violations.
The COA said the trial court also engaged in its own fact-finding in the case, which it should not have done. “Instead of analyzing the record to determine whether substantial evidence supported the Review Committee’s decision, the trial court concluded the plaintiffs ‘set forth evidence’ to support their position. The trial court applied the incorrect standard of review to the schools’ challenge, improperly substituted its own judgement for the IHSAA’s and erred by concluding the schools demonstrated a reasonable likelihood of success on the merits.”
The case is Indiana High School Athletic Association and Hammond Gavit High School v. Nasir Cade, et al., 45A03-1503-PL-84.