## Facts

- Nova High School played St. Thomas High School in an FHSAA regional semifinal baseball game governed by FHSAA rules.
- St. Thomas led after six innings.
- In the top of the seventh inning, Nova scored and took the lead.
- Before St. Thomas could bat in the bottom of the seventh, heavy rain made the field unplayable, and the umpires terminated play.
- The umpires declared St. Thomas the winner under FHSAA Rule 4-2-3, which provides that when a game is terminated after at least five completed innings and the teams have not had equal completed turns at bat, the score reverts to the end of the last completed inning.
- Because the sixth inning was the last completed inning and St. Thomas led at that point, the umpires treated St. Thomas as the winner.
- Vincent Coletti, a Nova player and team leader, sued the Florida High School Athletic Association, Inc. (FHSAA), seeking injunctive relief requiring FHSAA to schedule a resumption of the game.
- Coletti alleged the umpires should have applied Rule 4-2-4, which treats a game terminated early due to weather or other conditions—when a winner cannot be determined—as a suspended game to be continued later.
- Coletti did not ask FHSAA to review the umpires’ decision before filing suit, though FHSAA rules stated umpire decisions were final and protests were not allowed.

## Issues

1. Whether a student-athlete had standing to seek injunctive relief against FHSAA to correct a playoff game result affected by an alleged misapplication of FHSAA playing rules.
2. Whether the action should be dismissed for failure to exhaust internal FHSAA remedies, where FHSAA rules treated umpire decisions as final and barred protests.
3. Whether a court may review and remedy an alleged misapplication of written FHSAA rules affecting advancement in postseason play.
4. Whether the rain-terminated game (Nova leading after the top of the seventh, with no bottom of the seventh played) was governed by Rule 4-2-3 (revert to last completed inning) or Rule 4-2-4 (suspended game to be resumed).

## Decision

- The court rejected FHSAA’s dismissal arguments and reached the merits of the rules dispute.
- The court concluded the situation called for treatment of the contest as a suspended game under Rule 4-2-4, rather than declaring a winner under Rule 4-2-3.
- The court granted injunctive relief requiring FHSAA to schedule a resumption of the game from the point of termination.

## Legal Principles

- Courts ordinarily avoid re-officiating athletic contests, but they may intervene when a governing body or its officials fail to follow mandatory, written rules in a way that determines eligibility or advancement.
- A plaintiff is not required to pursue internal review that is unavailable in practice; exhaustion may be excused when association rules make the challenged decision final and provide no meaningful mechanism for correction.
- Standing may exist where the challenged action directly affects the plaintiff’s participation in postseason play and the requested relief targets enforcement of the association’s own rules.
- When an athletic association’s rules distinguish between a completed game and a suspended game, the remedy turns on the rule text and whether the game-ending event occurred before the contest reached a point where a winner can be determined under those rules.

## Conclusion

The circuit court held that the rain-stopped regional semifinal could not be finalized by reverting to the sixth-inning score under Rule 4-2-3 and instead had to be treated as a suspended game under Rule 4-2-4; it therefore granted injunctive relief requiring FHSAA to schedule the game’s resumption.


Coletti v. Florida High School Athletic Association, Inc., 23 Fla. L. Weekly Supp. 38a (2015)