## Facts

- Jon English, a college football player, initially enrolled at Michigan State University and sought to play quarterback.
- After limited prospects, he transferred from Michigan State (a four-year institution) to a junior college in Pennsylvania.
- He then transferred to Iowa State University (a four-year institution) and sought to compete there for the 1981–1982 season.
- After limited playing success at Iowa State, he transferred to a junior college in Louisiana.
- He later sought to enroll at Tulane University in fall 1983 and play football there; his father was Tulane’s football coach.
- The NCAA applied its transfer-eligibility bylaw requiring a “year in residence” after transfer from a student-athlete’s first four-year institution before competing at another four-year institution, absent an exception.
- The NCAA interpreted the rule to require that a full year elapse since English’s transfer from his first four-year school (Michigan State), notwithstanding intermediate enrollment at junior colleges.
- The NCAA declared English ineligible to compete at Tulane; he pursued internal reconsideration and then filed suit seeking to overturn the ineligibility ruling.

## Issues

1. Whether the NCAA correctly interpreted and applied its transfer-eligibility “year in residence” bylaw to render English ineligible to compete at Tulane.
2. Whether a Louisiana court may set aside the NCAA’s eligibility decision as arbitrary, capricious, unreasonable, or contrary to public policy, and whether that standard was met.

## Decision

- The Louisiana Court of Appeal, Fourth Circuit affirmed the trial court’s judgment for the NCAA.
- The court upheld the NCAA’s interpretation that the required waiting period runs from the transfer from the first four-year institution and was not eliminated by intervening junior-college attendance.
- The court held the NCAA’s rule and its application to English were not arbitrary, capricious, or unreasonable.
- The court rejected the contention that enforcing the bylaw against English violated Louisiana public policy.
- English remained ineligible to play football at Tulane for the disputed season.

## Legal Principles

- Courts generally refrain from interfering in the internal affairs of private voluntary associations and will intervene only when the association acts arbitrarily, capriciously, unlawfully, contrary to public policy, or contrary to its own rules.
- NCAA member institutions voluntarily bind themselves by contract to comply with NCAA eligibility regulations, and the NCAA has authority to interpret and enforce those rules within its governance structure.
- A transfer-eligibility “year in residence” rule may be enforced according to its text and purpose, including to deter serial transfers for athletic advantage and to support academic and competitive integrity.
- A litigant seeking judicial relief from an NCAA eligibility decision must show more than hardship or disputed fairness; relief requires a demonstrated lack of rational basis, rule violation, illegality, or conflict with public policy.

## Conclusion

The court affirmed the NCAA’s determination that English was ineligible under the transfer “year in residence” bylaw, holding that the NCAA’s interpretation fell within its authority and that neither the rule nor its application justified judicial interference under Louisiana standards governing private associations.


English v. Nat’l Collegiate Athletic Ass’n, 439 So. 2d 1218 (La. Ct. App. 4th Cir. 1983)