Tiffany v. Arizona Interscholastic Association, Inc.

John Tiffany (plaintiff) turned 19 years old before September 1 of his senior year at St. Mary’s High School (St. Mary’s). Tiffany had been held back in elementary school due to a learning disability. Tiffany participated in athletics throughout his schooling and wanted to participate in interscholastic athletics his senior year. Competing in interscholastic athletics motivated Tiffany to maintain a minimum required grade-point average. St. Mary’s belonged to the Arizona Interscholastic Association (AIA) (defendant), which precluded any student who turned 19 before September 1 of the school year from participating in interscholastic athletics (age-eligibility rule). The AIA’s bylaws allowed its executive board to grant a waiver of the age-eligibility rule on an individual basis due to circumstances beyond the student’s control (hardship waiver). The AIA held a hearing in Tiffany’s case and denied his request for a hardship waiver because the AIA did not make exceptions to the age-eligibility rule as a matter of policy. Tiffany sued the AIA, arguing that the AIA’s actions violated due process. The trial court ruled in Tiffany’s favor, allowing him to play interscholastic sports his senior year. The AIA appealed. On appeal, the AIA conceded that Tiffany’s inability to meet the age-eligibility rule was due to circumstances beyond his control.