## Facts

- Luis Cruz, a 19-year-old Ridley High School student with an intellectual disability, remained in high school beyond the typical age due to disability-related delayed entry and extended schooling.
- The Pennsylvania Interscholastic Athletic Association (PIAA), a statewide regulator of interscholastic athletics, enforced an eligibility rule making students ineligible upon turning 19, with no waiver mechanism.
- PIAA asserted the age rule served safety and competitive-fairness goals and preserved opportunities for customary high-school-age students.
- Cruz participated in football, wrestling, and track; the record indicated no meaningful safety risk or unfair advantage in football or track and no evidence of heightened risk in wrestling.
- Cruz sought an exception, arguing his age ineligibility was caused by his disability and that athletics were important to his special-education program and transition goals.
- PIAA denied relief, citing uniformity concerns and administrative burden from individualized exceptions, despite having waiver mechanisms for some other eligibility rules.
- Cruz and the Ridley School District sued, claiming the no-waiver age rule violated the ADA when applied to disability-related over-age status.

## Issues

1. Whether Cruz was an individual with a disability protected by the ADA in the context of school athletics.
2. Whether PIAA was subject to ADA obligations for its administration of interscholastic athletics.
3. Whether enforcing a maximum-age rule with no individualized waiver process unlawfully discriminated on the basis of disability or failed to provide a reasonable modification.
4. What relief was appropriate if an ADA violation was shown.

## Decision

- The court held that applying PIAA’s age rule to Cruz without any opportunity for an individualized waiver violated the ADA.
- The court did not invalidate the age rule itself, but required PIAA to permit Cruz to apply for a waiver.
- The court ordered PIAA to evaluate eligibility through an individualized process rather than a categorical bar.

## Legal Principles

- The ADA requires covered entities to make reasonable modifications to policies, practices, or procedures when necessary to avoid disability-based discrimination, unless the modification would fundamentally alter the program.
- Facially neutral rules may violate the ADA when applied inflexibly in a manner that disproportionately excludes individuals because of disability-related circumstances.
- Individualized assessment is generally required where a blanket rule excludes a person whose disability-related condition does not implicate the rule’s core safety or fairness rationale.
- Administrative convenience and uniformity concerns, standing alone, do not excuse the absence of a targeted waiver process, particularly where similar waiver mechanisms already exist.

## Conclusion

The court concluded that the ADA required PIAA to provide an individualized waiver mechanism for disability-related age ineligibility, because categorical exclusion without consideration of safety and competitive impact in the particular case was an unreasonable failure to modify its eligibility policy.


Cruz ex rel. Cruz v. Pennsylvania Interscholastic Athletic Ass'n, 157 F. Supp. 2d 485 (E.D. Pa. 2001)