National Collegiate Athletic Association v. Smith
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''National Collegiate Athletic Association v. Smith'', 525 U.S. 459 (1999), was a case in which the
Supreme Court of the United States The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...
ruled that the
NCAA The National Collegiate Athletic Association (NCAA) is a nonprofit organization that regulates student athletics among about 1,100 schools in the United States, Canada, and Puerto Rico. It also organizes the athletic programs of colleges an ...
's receipt of dues payments from
colleges A college (Latin: ''collegium'') is an educational institution or a constituent part of one. A college may be a degree-awarding tertiary educational institution, a part of a collegiate or federal university, an institution offerin ...
and
universities A university () is an institution of higher (or tertiary) education and research which awards academic degrees in several academic disciplines. Universities typically offer both undergraduate and postgraduate programs. In the United States, t ...
which received federal funds, was not sufficient to subject the NCAA to a lawsuit under
Title IX Title IX is the most commonly used name for the federal civil rights law in the United States that was enacted as part (Title IX) of the Education Amendments of 1972. It prohibits sex-based discrimination in any school or any other educat ...
..


Background

Renee M. Smith, an intercollegiate volleyball player, had played volleyball for two seasons from the fall of 1991 to 1993 at St. Bonaventure University. Smith graduated from St. Bonaventure University during the 1994 - 1995 athletic year and later enrolled in a postgraduate program at the University of Pittsburgh for the 1995 - 1996 athletic year. Smith had hoped to play volleyball for the
University of Pittsburgh The University of Pittsburgh (Pitt) is a public state-related research university in Pittsburgh, Pennsylvania. The university is composed of 17 undergraduate and graduate schools and colleges at its urban Pittsburgh campus, home to the universit ...
but was denied athletic eligibility by the NCAA on the basis of its Post Baccalaureate restrictions. Smith and The University of Pittsburgh applied for a waiver from the National Collegiate Athletic Association, to lift the restrictions on the athletic eligibility of graduate students. However the waiver was denied by the NCAA.


Procedural history

In August 1996, Smith filed a lawsuit ''pro se'' against the NCAA, alleging that the NCAA’s decision to not allow her to play intercollegiate volleyball at the University of Pittsburgh and Hofstra University on the basis of her sex, in that the NCAA grants more waivers for athletic eligibility restrictions to male than female post graduate student athletes. The NCAA attempted to have the case dismissed on the grounds that it did not receive federal assistance. This would exempt the NCAA from compliance with Title IX which states that "No person in the United States shall, on the basis of sex, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any education program or activity receiving Federal financial assistance..." The district court dismissed the case, claiming that Smith could not claim that Title IX was applicable. Smith then amended her claim. The Court of Appeals for the Third Circuit later reversed the district court's decision. The NCAA then petitioned for Supreme Court review. They claimed that the court decision did not agree with the previous court case ''Department of Transportation v. Paralyzed Veterans of America'', which prohibits discrimination against any handicapped person in “any program or activity receiving any federal financial assistance.” The Supreme Court granted ''
certiorari In law, ''certiorari'' is a court process to seek judicial review of a decision of a lower court or government agency. ''Certiorari'' comes from the name of an English prerogative writ, issued by a superior court to direct that the record of ...
'', in order to find out if a private organization such as the NCAA, that does not receive federal financial assistance, can be subject to Title IX simply because it receives funds from organizations that do receive federal financial assistance, making the NCAA indirectly federally funded.


Opinion of the Court

The Supreme Court came to a unanimous decision ruling that the NCAA cannot be sued under Title IX of the Education Amendments of 1972 and remanded the case for further proceedings complying with this decision. The Supreme Court held that allegations did not exist that state that the NCAA uses the funds from its institutions that are federally funded, to provide any students with any form of financial aid. They stressed that only institutions that are federally funded directly can be subject to coverage by Title IX. The NCAA was represented on its appeal to the Supreme Court by
John Roberts John Glover Roberts Jr. (born January 27, 1955) is an American lawyer and jurist who has served as the 17th chief justice of the United States since 2005. Roberts has authored the majority opinion in several landmark cases, including ''Nati ...
, who would later become Chief Justice of the United States in 2005.


See also

*''
NCAA v. Board of Regents of the University of Oklahoma ''NCAA v. Board of Regents of the University of Oklahoma'', 468 U.S. 85 (1984), was a case in which the Supreme Court of the United States held that the National Collegiate Athletic Association (NCAA) television plan violated the Sherman and Cla ...
'' *
List of United States Supreme Court cases, volume 525 This is a list of all the United States Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court ca ...


References


External links

* {{caselaw source , case = ''NCAA v. Smith'', {{ussc, 525, 459, 1999, el=no , cornell =https://www.law.cornell.edu/supct/html/98-84.ZO.html , courtlistener =https://www.courtlistener.com/opinion/118263/national-collegiate-athletic-assn-v-smith/ , findlaw = https://caselaw.findlaw.com/us-supreme-court/525/459.html , googlescholar = https://scholar.google.com/scholar_case?case=10967313423074816027 , justia =https://supreme.justia.com/cases/federal/us/525/459/case.html , loc =http://cdn.loc.gov/service/ll/usrep/usrep525/usrep525459/usrep525459.pdf , oyez =https://www.oyez.org/cases/1998/98-84 United States Supreme Court cases United States Supreme Court cases of the Rehnquist Court 1999 in American sports 1999 in United States case law College volleyball in the United States National Collegiate Athletic Association litigation United States gender discrimination case law University of Pittsburgh Women and sports History of women in Pennsylvania