Tennessee Secondary School Athletic Assn. v. Brentwood Academy, 551 U.S. 291 (2007)

In the case of Tennessee Secondary School Athletic Assn. v. Brentwood Academy, the underlying dispute arose from the enforcement of a rule by the Tennessee Secondary School Athletic Association (TSSAA) that prohibited high school coaches from recruiting middle school athletes. In April 1997, Brentwood Academy's football coach sent a letter to a group of eighth-grade boys inviting them to attend spring practice sessions, which was deemed a violation of TSSAA's anti-recruiting rule. Although the boys had signed a contract indicating their intent to attend Brentwood, they had not yet enrolled according to TSSAA's definition, which required attendance at school for three days. The TSSAA sanctioned Brentwood Academy for this violation, asserting that the coach had ample notice of the prohibition against such conduct. The procedural history of the case began when Brentwood Academy challenged TSSAA's enforcement in federal court under 42 U.S.C. §1983. Brentwood made two claims: that the enforcement of the anti-recruiting rule constituted state action violating the First and Fourteenth Amendments, and that TSSAA's handling of its appeal denied the school due process. Initially, the District Court ruled in favor of Brentwood, but the Court of Appeals reversed this decision, determining that TSSAA was a private voluntary association and did not act under color of state law. The Supreme Court granted certiorari, ultimately reversing the Court of Appeals' decision and affirming the District Court's ruling on the state action issue. On remand, the District Court again ruled for Brentwood, leading to another appeal by TSSAA, which was affirmed by the Court of Appeals. The relevant background context includes the TSSAA's long-standing policy against "undue influence" in recruiting middle school students, a rule that has been in place since the early 1950s. The case highlights the tension between athletic associations' regulatory authority and the rights of schools and their coaches under the First Amendment. The Court's decision ultimately addressed whether the TSSAA's actions constituted state action and whether Brentwood Academy was afforded due process in the adjudication of its appeal.

Whether the enforcement of a rule prohibiting high school coaches from recruiting middle school athletes violates the First Amendment and whether the sanction imposed on Brentwood Academy for violating that rule was preceded by a fair hearing.

The judgment is affirmed.