## Facts

- The Arkansas Activities Association (AAA) is a voluntary, unincorporated association of roughly 495 public and private schools that regulates interscholastic athletics and activities.
- In September 1980, the AAA adopted an age rule barring senior high participation if a student’s nineteenth birthday falls on or before October 1 of the school year.
- The AAA also adopted a grandfather clause allowing a waiver for students made ineligible due to pre-September 1980 events, permitting participation until age 20 if “normal progression” occurred after 1980 and the executive director approved.
- Shane William Meyer (born July 10, 1971) entered public school before September 1980.
- At his mother’s request, Meyer repeated fifth grade in 1983–84; the repetition was not required by school officials.
- Because of the repetition, Meyer turned 19 before October 1 of his senior year (1990–91), making him ineligible under the age rule.
- In February 1990, Meyer sought a hardship exception from the AAA’s executive director; the request was denied, and the denial was affirmed by the AAA Executive Committee in March 1990.
- Meyer sued for injunctive relief to prevent enforcement of the age rule and to prevent forfeitures by his school if he participated.
- The chancery court permanently enjoined the AAA, finding the grandfather clause arbitrary and capricious as applied to Meyer and concluding the AAA acted arbitrarily in denying relief.

## Issues

1. Under what circumstances may a court review and set aside eligibility determinations and internal rules of a voluntary interscholastic activities association?
2. Whether the AAA’s age rule, its grandfather clause (including the “normal progression” condition), and the denial of Meyer’s hardship request were arbitrary, capricious, or unlawful so as to justify injunctive relief.

## Decision

- The Supreme Court of Arkansas reversed the chancery court and remanded with directions to dissolve the injunction.
- The court held that courts generally defer to voluntary associations’ eligibility rules and decisions and intervene only upon a showing such as fraud, bad faith, arbitrary or capricious action, or violation of law.
- The court concluded the age rule served legitimate purposes (fairness and safety) and was not arbitrary merely because it drew a firm eligibility line.
- The court upheld the grandfather clause as a rational transitional measure and held the “normal progression” condition was a reasonable limitation on waivers.
- Because Meyer repeated a grade after adoption of the rule, he did not satisfy “normal progression,” and the AAA’s denial of a waiver and hardship exception was not shown to be arbitrary, capricious, or in bad faith.

## Legal Principles

- Courts are reluctant to interfere with the internal affairs of voluntary associations and will not substitute judicial policy preferences for the association’s judgments.
- Judicial intervention in association eligibility matters is limited to circumstances such as fraud, lack of jurisdiction, bad faith, arbitrary or capricious action, or conduct contrary to law or public policy.
- An eligibility rule is not unconstitutional or arbitrary solely because it applies harshly to an individual; rational line-drawing in rules governing competition may be upheld.
- Transitional waiver provisions may be conditioned on objective limits (such as “normal progression”) to prevent open-ended exceptions and preserve uniform enforcement.

## Conclusion

The Arkansas Supreme Court held that the AAA’s age-based eligibility rule and its grandfather clause were rational and lawfully applied to Meyer, and that the chancery court exceeded permissible judicial oversight by enjoining enforcement absent proof of arbitrariness, bad faith, or illegality.


Ark. Activities Ass’n v. Meyer, 805 S.W.2d 58 (Ark. 1991)