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Georgia High School Assn. v. Waddell – Case Brief

Georgia High School Assn. v. Waddell, 248 Ga. 542, 285 S.E.2d 7 (1981).

Facts: In the course of a high school football game, a “roughing the kicker” penalty was not properly assessed. A dispute arose over whether the coaches properly protested the referee’s error. The high school filed a written protest with the Executive Secretary of the Georgia High School Association (P). The Association denied the protest on the grounds that an official protest had not been made to the referee immediately following the play. The Association’s decision was affirmed by the state Executive Committee.

Parents of students at the high school (Waddell, P) filed suit in Superior Court. The court found that the referee had been in error and that the error had been properly protested, and that Ps had a property right in having the game played according to the rules. The court entered judgment in favor of P and ordered that the game be replayed from the point of the error. D filed a motion for supersedeas and the trial court’s order was suspended pending further order.

Issue: Do rights under Equal Protection include the right to have a football game played by the rules?

Holding and Rule: No. Rights under Equal Protection do not include the right to have a football game played by the rules.

The court held that there is no state action in determining rule errors in High School football games. A high school football player does not have a protected right to participate in interscholastic sports, and there is no protectable property interest which would give rise to a due process claim. The court held that courts of equity do not have authority to review decisions of football referees because they are not justiciable controversies.

Disposition: For D; stay reaffirmed.


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