## Facts

- The Georgia High School Association (GHSA) governed interscholastic athletics for member high schools, including Region 5 AAAA football.
- In a 1981 game between R.L. Osborne High School and Lithia Springs High School, officials assessed a 15-yard “roughing the kicker” penalty against Lithia Springs but erroneously failed to award Osborne an automatic first down as required by governing rules.
- After the mistaken enforcement, Osborne punted again, Lithia Springs scored, and Lithia Springs ultimately won 16–7, affecting playoff advancement.
- Osborne pursued GHSA’s internal protest process; GHSA bodies acknowledged the officiating error but denied relief based on the association’s protest requirements.
- Parents of Osborne players sued GHSA in superior court seeking judicial relief affecting the game’s consequences and playoff participation.
- The trial court concluded it had jurisdiction, found the rule misapplication, held the players had a “property right” to a game played according to the rules, found an equal protection violation, and ordered relief allowing Osborne to participate in playoffs.

## Issues

1. Whether a referee’s misapplication of a game rule presents a justiciable controversy permitting a court to alter game consequences and association determinations.
2. Whether high school players (and parents) have a constitutionally protected property interest in participating in interscholastic athletics or in having games officiated correctly, sufficient for due process or equal protection claims.
3. Under what circumstances courts may intervene in decisions of a voluntary high school athletic association.

## Decision

- The Supreme Court of Georgia reversed the trial court’s order.
- The court held that high school players have no constitutionally protected property right to participate in interscholastic sports, and a referee’s rule error does not create a due process claim.
- The court rejected the equal protection theory because an isolated officiating mistake is not discriminatory state action or an impermissible classification.
- The court held that routine officiating errors and an association’s internal resolution of them are not grounds for judicial intervention absent fraud, collusion, arbitrary and capricious action, or violation of a constitutional or statutory right.
- The effect was to leave intact GHSA’s decision and the game result’s playoff implications.

## Legal Principles

- Participation in interscholastic athletics is not a constitutionally protected property (or liberty) interest that supports due process claims.
- A mistaken application of athletic rules by officials, without more, does not establish an equal protection violation.
- Courts generally will not review or overturn athletic contest outcomes or an athletic association’s internal determinations based on officiating errors.
- Judicial intervention in voluntary association decisions is limited to situations involving fraud, collusion, arbitrary or capricious conduct, or a clear constitutional or statutory violation.

## Conclusion

The court held that a high school football officiating error, even if admitted, does not create a constitutional claim or justify judicial alteration of a game’s consequences; absent fraud or illegality, disputes over rule enforcement and playoff determinations remain for the athletic association rather than the courts.


Ga. High Sch. Ass'n v. Waddell, 248 Ga. 542, 285 S.E.2d 7 (Ga. 1981)