Pottgen v. The Missouri State High School Activities Association case brief

Pottgen v. The Missouri State High School Activities Association case brief summary
40 F.3d 926 (1994)

CASE SYNOPSIS

Appellee disabled individual brought an action against appellant high school athletic association challenging its age limit under §504 of the Rehabilitation Act of 1973, codified at 29 U.S.C.S. § 794, Title II of the Americans with Disabilities Act (ADA), and 42 U.S.C.S. §1983. The United States District Court for the Eastern District of Missouri issued a preliminary injunction against the athletic association. The association appealed.

CASE FACTS
The disabled individual repeated two grades in elementary school due to learning disabilities. By his senior year, this delay made him too old to play interscholastic baseball under the athletic association's eligibility standards. The association argued that the disabled individual was not entitled to injunctive relief because he had no likelihood of success on the merits. The disabled individual contended that he was an "otherwise qualified individual" because waiver of the age limit was a reasonable accommodation based on his disability.

DISCUSSION

• The court held that the district court erred by granting the disabled individual an injunction because 
• (1) he was not an "otherwise qualified individual" under the Rehabilitation Act or the ADA as he could not meet the age requirement in spite of his disability and other than waiving the age limit, which was an essential requirement, no method was available which would have permitted him to satisfy the age limit, thus, no reasonable accommodations existed; and
• (2) he was unable to establish a civil rights violation under 42 U.S.C.S. §1983.

CONCLUSION
The court reversed the decision of the district court granting the disabled individual an injunction.

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