Matter of Samuel v. New York State Public High School Athletic Association, Inc., 67 N.Y.2d 672 (1986)

A voluntary association of local boards of education has the authority to promulgate rules regarding interscholastic athletics, provided such rules are rational and do not violate fundamental constitutional rights.

Summary

The New York Court of Appeals upheld the decision of the Appellate Division, finding that the New York State Public High School Athletic Association (NYSPHSAA)’s rule limiting participation in club and interscholastic athletics was rational and did not violate any fundamental constitutional right of family autonomy. The court also addressed the petitioner’s argument that the authority to promulgate the rule was improperly delegated to the NYSPHSAA. The court found that such authority was implicit in the Commissioner’s regulations, which allow local boards of education to create additional rules consistent with the basic code and to consult with representatives of other school systems for rule recommendations. The NYSPHSAA, as a voluntary association of local boards, acted within the scope of this delegated authority.

Facts

The New York State Public High School Athletic Association, Inc. (NYSPHSAA) implemented a rule limiting participation in club and interscholastic athletics. The petitioner challenged this rule, arguing it violated constitutional rights and was improperly promulgated.

Procedural History

The Appellate Division upheld the rule. The petitioner appealed to the New York Court of Appeals.

Issue(s)

1. Whether the NYSPHSAA rule limiting participation in club and interscholastic athletics is rational and violates any fundamental constitutional right of family autonomy.
2. Whether authority was improperly delegated to the NYSPHSAA to promulgate the outside competition rule.

Holding

1. No, because the rule is rational and does not violate any fundamental constitutional right of family autonomy.
2. No, because the authority to promulgate the rule is implicit in the provisions contained in Part 135 of the Commissioner’s regulations (8 NYCRR).

Court’s Reasoning

The court agreed with the Appellate Division that the rule was rational and did not violate any fundamental constitutional right. Regarding the delegation of authority, the court reasoned that the Commissioner’s regulations (8 NYCRR 135.4[c][7][i][a]) require local boards of education to conduct interscholastic athletics in accordance with the Commissioner’s regulations, allowing them to create additional consistent rules. The regulations also permit boards to consult with representatives of other school systems and make rule recommendations. The NYSPHSAA, as a voluntary association of local boards of education, comprising representatives of various school boards, exercised the authority conferred upon member schools by the Commissioner of Education when it promulgated the rule. The court found further support for this view in the regulations’ definition of an athletic association as a “central organization of schools joined together on a large geographic area or statewide basis for the purpose of governing athletic programs for all its member schools” (8 NYCRR 135.1[f]), recognizing that local school boards may form an association such as NYSPHSAA to regulate interscholastic athletic programs. The court emphasized that “Local boards of education are required to conduct interscholastic athletics in accordance with the Commissioner’s regulations ‘and such additional rules consistent with this basic code as may be adopted by such boards relating to items not covered specifically in’ it and the regulations provide also that a ‘board may authorize appropriate staff members to consult with representatives of other school systems and make recommendations to the board for the enactment’ of rules regulating athletic activities (8 NYCRR 135.4 [c] [7] [ij [a]).”