Cruz v. Pennsylvania Interscholastic Athletic Association, Inc.

Luis Cruz (plaintiff) was a 19-year-old intellectually disabled student at Ridley High School. Because of his disability, Cruz entered school later and remained longer than typical students. During his first three years at Ridley High School, Cruz participated in football, wrestling, and track. However, the Pennsylvania Interscholastic Athletic Association (PIAA) (defendant) then declared Cruz ineligible. The PIAA, which regulated interscholastic competition for about 1,350 Pennsylvania schools, permitted students to participate in eight semesters of interscholastic sports but barred students from participating once they turned 19. The rule was intended to protect younger athletes from the risks of competing with older, stronger, and more experienced athletes, prevent unfair competitive advantage, preserve team spots for students of customary age, and maintain uniform eligibility standards. Cruz was not a standout athlete. He was five feet three inches and weighed 130 pounds. In football, he played on a limited basis, and his participation was largely for inclusion. Cruz posed no safety risk or competitive advantage, and because the team had a no-cut policy, his participation did not displace any other student. In track, Cruz was likewise a marginal participant. He consistently finished behind qualifying times, never scored points, and again displaced no one. Wrestling was the only sport where Cruz might have had a competitive advantage. He had solid skills and a strong record; however, many wrestlers were better, and he posed no safety risk. Cruz requested a waiver of PIAA’s age rule, stressing that he posed no safety risk or competitive advantage. The director of special-education services added that continued participation was critical for Cruz’s social, emotional, and employment development. While waivers existed for other eligibility rules, including transfer waivers and eight-term waivers, none existed for the age rule. The PIAA denied Cruz’s request. Cruz sued the PIAA, asserting that strict enforcement of the age rule violated the Americans with Disabilities Act (ADA). The PIAA responded that no waiver was available because evaluating competitive advantage on a case-by-case basis would be overly burdensome.