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Brentwood Academy v. Tennessee Secondary School Athletic Association
531 U.S. 288
Facts: The Brentwood Academy v. Tennessee Secondary School case dealt with a situation surrounding constitutional law and state action. The Tennessee Secondary School Athletic Association was a not-for-profit private corporation created to regulate public and private high school interscholastic sports in the state of Tennessee. In 1977, the TSSAA board found Brentwood Academy, a private high school, to have violated a TSSAA rule that prohibited undue influence in the recruitment of athletes. This led to Brentwood Academy athletic programs being placed on probation for 4 years, stating that the boys’ basketball and football teams were ineligible to compete in post-season play for 2 years, and imposed a 3,000 fine. Brentwood Academy claimed the actions and implementation of this rule were a violation of their First and Fourteenth Amendment rights and that enforcement of the rule was state action, leading them to sue the Tennessee Secondary School Athletic Association. The District Court ruled TSSAA to be a state actor and went forward with the decision of Brentwood Academy and urged the Tennessee Secondary School Athletic Association from enforcing the rule. The TSSAA is composed of almost all the state of Tennessee’s public high schools and 55 private high schools all joining on their own. Each school that was affiliated with TSSAA was represented by a faculty member who had a say in the board of TSSAA and met mostly during school hours while providing a large portion of the financials that supported the association. The TSSAA’s staff and board were considered state employees, and their rules and regulations were reviewed and approved by the state. Even with the involvement mainly being done by the schools themselves, with the participation of school officials, the entwinement of state actors in TSSAA regulation of state inner school sports reasonings led to the Supreme Court of Appeals judgment to reverse the District Court’s Judgement.
Issue: Could the actions of the Tennessee Secondary School Athletic Association be considered state action when implementing rules against its member Brentwood Academy and other public and private schools.
Holding: Yes, this private association was considered a state actor and is subject the civil rights laws due to the symbiotic relationship with the public schools.
Rationale: This case demonstrates the entwinement concept where a private organization’s action is considered to be a state action since they are very closely working with the state. It was stated that the Tennessee Secondary School Athletic Association was engaging in state action when enforcing the punishment of Brentwood Academy’s recruitment situation since there was a symbiotic relationship with the state. There was no substantial action to show unfairness in applying and enforcing these rules, standards, and regulations; since state action is only found if there is a close connection between the state and the action that is being challenged or tested.
Important Information: This case is important because the court found the recruiting rule enforced by the Tennessee Secondary School Athletic Association didn’t violate the use of the First and Fourteenth Amendments and created a new insight into state action.
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