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Ganden v. NCAA

United States District Court for the Northern District of Illinois
1996 WL 680000 (1996)


Facts

Chad Ganden (plaintiff) was recruited by Michigan State University to swim on the school’s team. However, Ganden’s learning disability had seriously hindered his grade point average (GPA) during high school. From his freshman through junior years in high school, Ganden’s cumulative GPA was 2.09. After his disability was discovered at the end of his junior year, Ganden’s high school implemented an individualized learning plan in an effort to assist Ganden with his courses. As a result of the educational assistance, Ganden’s GPA for his senior year was 3.0. However, Ganden’s cumulative GPA of 2.136 was still below the National Collegiate Athletic Association’s (NCAA) (defendant) requirement of 2.275. Additionally, Ganden had completed only 11 of the required 13 core high school courses required by the NCAA. Michigan State applied to the NCAA to waive its requirements for Ganden due to his disability. Although an NCAA subcommittee included additional courses so that Ganden could meet the core course requirement, his GPA was still below NCAA’s requirement. As a result, Ganden was a “partial qualifier” and was eligible to receive a swimming scholarship and practice with the team, but not eligible to compete during his freshman year. Ganden asked the NCAA for additional modifications which would have increased his GPA over the NCAA requirement, but was denied. Ganden filed suit in U.S. District Court alleging violations of the Americans with Disabilities Act (ADA) and seeking an injunction to allow him to compete during his freshman year.

Rule of Law

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Issue

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Holding and Reasoning (Manning, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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