Duffley and Snow Case Comparison 1

Duffley and Snow Case Comparison

Elizabeth Valade

Southern New Hampshire University

Sport Law

SPT-610

Dr. Brent Estes

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DUFFLEY AND SNOW CASE COMPARISON 2

DUFFLEY AND SNOW CASE COMPARISONDUFFLEY AND SNOW CASE

COMPARISON

Duffley v. N.H. Interscholastic Athletics Association Inc. 122 N.H. 484 (1982)

Facts

Robert Duffley (plaintiff) was a member of the Trinity High School basketball team.

Trinity High School is a member of the New Hampshire Interscholastic Athletic Association, Inc

(NHIAA) (defendant). As a sophomore in 1978-1979 school year, he became ill and stopped

participating in both basketball and academics for the remainder of the year on the advice of his

doctor. He returned to school for the 1979-1980 school year and was allowed to participate in

athletics again. During his senior season, 1980-1981, the NHIAA ruled him ineligible to compete

in the spring semester, based upon a rule Article II, Section 12, stating that no one is eligible to

compete for more than 8 semesters consecutively.

Issues

Was Duffley’s due process by the 14th amendment violated by NHIAA for ruling him

ineligible to compete?

Does Duffley have a legal right to participate in interscholastic events?

Are the actions of the NHIAA considered a state action regarding the Duffley?

Holding

The court ruled on the side of the plaintiff because the NHIAA did not a give reasonable

response to why Duffley was ineligible to compete in the spring semester of his senior year. The

court ruled that “denying the plaintiff's eligibility was unlawful and is therefore invalid” (Duffley

v. N.H. Interscholastic Athletics Association Inc., 1982). In addition, the committee denied the

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DUFFLEY AND SNOW CASE COMPARISON 3

requests for additional eligibility by the principal without holding a hearing. The court stated the

“removal from a particular class, an athletic team, a club, or any extracurricular activity, would

each require the satisfactory of due process” (Duffley v. N.H. Interscholastic Athletics

Association Inc., 1982).

Rationale

The Court found that NHIAA role was a state action and thus Duffley should be awarded

due process as granted under his 14th amendment constitutional rights because under the

Minimum Standards and Recommended Practices For New Hampshire High Schools, Grades 9-

12, athletics are recognized as an integral part of the entire school program. The NHIAA did not

provide reasons for the denial until the night before the trial. One of the main reasons for the

denial was the concern of his illness being legitimate, which the defendant provided medical

documentation for.

Snow v. N.H. Interscholastic Athletics Association Inc. 122 N.H. 735 (1982)

Facts

During the 800m track event, Ron Snow (defendant) was allegedly fouled causing him to

finish in seventh place which was outside the top five finish placing required to compete in an

additional event called the “Meet of Champions”. At the time of the incident, there were no

officials near the violation therefore, the meet director could not determine if the foul indeed

occurred. The meet director did petition the NHIAA (defendant) to allow Snow to participate in

the follow-on event. The NHIAA denied the petition resulting in Snow filing legal action against

the NHIAA. The lower court, based on the proceedings of Duffley v. N.H. Interscholastic

Athletics Association Inc. (1982), granted the right to the plaintiff to participate in the “Meet of

Champions”. The NHIAA appealed this decision, and the court held an emergency telephone

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DUFFLEY AND SNOW CASE COMPARISON 4

session the morning of the follow-on meet, in which it found that Snow’s rights were not

violated.

Issues

Was Snow’s due process by the 14th amendment violated by NHIAA for ruling him

ineligible to compete in the “Meet of Champions”?

Is the ruling in Duffley v. NHIAA Inc. the proper precedent legal opinion for this case?

Holding

The court sided with the NHIAA in this case determining Snow’s right to due process

were not violated by the NHIAA. The superior court found that the lower court relied too much

on the ruling in Duffley v. N.H. Interscholastic Athletics Association Inc. and not the

independent facts of this case.

Rationale

The court determined that reliance on Duffley v. N.H. Interscholastic Athletics

Association Inc. (1982) was incorrect since the previous case was based on eligibility not an

umpire or referee call during an event. Duffley v. N.H. Interscholastic Athletics Association Inc.

(1982) was about an eligibility determination for an entire semester. Additionally, allowing the

courts to become involved in a referee or umpire situation would cause a major disruption in

sports because it would set a precedent that legal proceedings can occur when a sports call is

disagreed upon.

Case Comparison

Both the cases are premised on procedural due process deals with the process used to

enforce the rule/regulation (Cotton, 2017). According to the Cornell School of Law (n.d.) “The

Constitution states only one command twice. The Fifth Amendment says to the federal

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DUFFLEY AND SNOW CASE COMPARISON 5

government that no one shall be "deprived of life, liberty or property without due process of

law." The Fourteenth Amendment, ratified in 1868, uses the same eleven words, called the Due

Process Clause, to describe a legal obligation of all states. These words have as their central

promise an assurance that all levels of American government must operate within the law

("legality") and provide fair procedures.” Due process required, at a minimum: (1) notice; (2) an

opportunity to be heard; and (3) an impartial tribunal (Mullane v. Central Hanover Bank, 1950).

Both Duffley v. N.H. Interscholastic Athletics Association Inc. (1982) and Snow v. N.H.

Interscholastic Athletics Association Inc. (1982) are about eligibility determinations by the

NHIAA, however the courts ruled that due process was violated only in the Duffley case. In the

Duffley case, the NHIAA did not allow for a hearing to occur before deciding (thus denying his

opportunity to be heard), however in the Snow case, the NHIAA did have a telephonic hearing

which is a unique circumstance but was the opportunity to be heard.

As stated in the case, Duffley was based on rules about procedures, attendance, and

whether this affected a student’s eligibility to participate in interscholastic athletics whereas the

Snow case involved eligibility for a single event involving a potential foul. Because the Snow

case was not based on procedures, it is not a state action and therefore due process does not need

to be granted before a decision is made.

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DUFFLEY AND SNOW CASE COMPARISON 6

References

Cornell School of Law. (n.d.). Due process. LII / Legal Information Institute.

https://www.law.cornell.edu/wex/due_process

Cotten, D. J., & Wolohan, J. T. (2017). Law for Recreation & Sport Managers (8th ed). Dubuque,

IA: Kendall Hunt.

Duffley v. N.H. Interscholastic Athletics Association Inc. 122 N.H. 484 (1982)

https://www.leagle.com/decision/1982606122nh4841499

Mullane v. Central Hanover Bank & Trust Co., 339 U.S. 306 (1950)

https://supreme.justia.com/cases/federal/us/339/306/

Snow v. N.H. Interscholastic Athletics Association Inc. 122 N.H. 735 (1982)

https://www.leagle.com/decision/1982857122nh7351686

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