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Washington v. Indiana High School Athletic Association, Inc.

United States Court of Appeals for the Seventh Circuit
181 F.3d 840 (1999)


Eric Washington (plaintiff) was a student with a learning disability living in Indiana. During elementary school and middle school, Washington was often allowed to advance to the next grade despite academic failings. However, Washington repeated the eighth grade. Even though Washington still earned failing grades during his second eighth-grade year, Washington was permitted to advance to ninth grade at Lafayette Jefferson High School at the beginning of the second semester of the 1994-95 academic year. Washington continued to earn poor grades, and a school counselor suggested that Washington drop out of high school. Washington took that advice and dropped out. Subsequently, Washington met Chad Dunwoody, the basketball coach at Central Catholic High School (CCHS) (plaintiff). Dunwoody encouraged Washington to attend CCHS and play basketball. Dunwoody also became Washington’s academic mentor. Washington began attending CCHS during the 1997-98 academic year. For the first time, Washington was diagnosed as learning disabled. However, the Indiana High School Athletic Association (IHSAA) (defendant) had a rule that limited athletic eligibility to eight semesters following the student’s commencement of the ninth grade. Under this rule, Washington would lose eligibility after the first semester of the 1998-99 academic year. The purposes of the rule were to discourage redshirting, protect student safety, promote competitive equality, and promote the idea that academics should take priority over athletics. CCHS applied for a waiver of the rule, and IHSAA denied the waiver. Washington and CCHS sued IHSAA, alleging that the failure to grant a waiver violated Title II of the Americans with Disabilities Act (ADA). Washington and CCHS requested a preliminary injunction to stop IHSAA from denying eligibility for the second semester of the 1998-99 academic year. The district court granted the preliminary injunction, and IHSAA appealed to the United States Court of Appeals for the Seventh Circuit.

Rule of Law


Holding and Reasoning (Ripple, J.)

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