Pryor v. National Collegiate Athletic Association

San Jose State University (SJSU), which was a member of the National Collegiate Athletic Association (NCAA) (defendant) recruited Kelly Pryor (plaintiff) to play soccer for SJSU beginning in the fall of 1999. Pryor signed a national letter of intent to attend SJSU, which conditioned her athletic scholarship and freshman participation in intercollegiate athletics on Pryor’s ability to satisfy the NCAA’s academic eligibility requirements for entering freshmen included in Proposition 16. Proposition 16 required a minimum standardized-achievement-test score and a minimum grade-point average. Pryor had a learning disability and failed to fully meet Proposition 16’s requirements, i.e., to be a “full qualifier.” On Pryor’s application for a waiver of the requirements due to her learning disability, she was deemed a “partial qualifier,” allowing her to retain her scholarship and to practice with SJSU’s soccer team but disallowing her from playing her freshman year. Under Proposition 16, Pryor could begin playing her sophomore year if she met minimum academic standards during her freshman year. Further, an NCAA bylaw granted learning-disabled student athletes five years to use their four years of athletic eligibility, in effect allowing learning-disabled students to play for four full years. In June 2000, Pryor sued the NCAA alleging that the NCAA’s eligibility requirements discriminated on the basis of disability under the Rehabilitation Act and the Americans with Disabilities Act (ADA). Pryor sought declaratory and injunctive relief. The NCAA filed a motion to dismiss the complaint based on Pryor’s lack of standing to bring her claims.