Gulf South Conference v. Boyd case brief

Gulf South Conference v. Boyd case brief summary
369 So.2d 553 (1979)

CASE SYNOPSIS

Defendant athletic association challenged the decision of the Circuit Court of Pike County (Alabama), which ruled that plaintiff college athlete was eligible to participate in varsity football at a university where he attended school. The association contended that the trial court did not have jurisdiction to intervene in the internal affairs of the association, and that the trial court's decision was contrary to its bylaws.

CASE FACTS
The college athlete had played one year of football under a scholarship at a university, which was a member of the athletic association. He quit after the first year, and eventually went to another university, but was ruled ineligible to play football by the association. In an action brought by the athlete, the trial court ruled that he was eligible to play.

DISCUSSION

• On appeal, the court affirmed, holding that the trial court had jurisdiction because the general non-interference doctrine concerning voluntary associations did not apply to a case involving a dispute between the college athlete and the athletic association. 
• The court based its ruling on the fact that the athlete was not a member of the association, so that the freedom of association principle did not exist. 
• Moreover, the athlete had no bargaining power concerning the rules or regulations, but was substantially affected by them, and was deprived of a property right of eligibility to participate in intercollegiate athletics. 
• The college athlete was ruled eligible to play because of his two-year absence from participation and the non-renewal of the initial scholarship.

CONCLUSION

The court affirmed the trial court's ruling in favor of the college athlete, holding that the trial court had jurisdiction. The athlete was ruled eligible to play.

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