## Facts

- Julian R. Boyd enrolled at Livingston University in fall 1975 on a full grant-in-aid football scholarship limited to one year and renewable only at Livingston’s discretion and Boyd’s acceptance.
- Boyd played football during the 1975 season, and both Boyd and Livingston fully performed the one-year scholarship.
- After the 1975–76 year, Livingston offered in writing to renew Boyd’s scholarship for 1976–77, but Boyd did not accept the renewal.
- Boyd enrolled at Troy State University (TSU) and sought to play varsity football there.
- The Gulf South Conference (GSC), an unincorporated athletic conference of member institutions including TSU, applied its eligibility rules to Boyd and treated his move as raising transfer-related eligibility restrictions.
- Boyd filed a declaratory judgment action in the Circuit Court of Pike County seeking a declaration that, under GSC rules, he was eligible to participate in varsity football at TSU.

## Issues

1. Whether a declaratory judgment action presented a justiciable controversy allowing a state court to decide an athlete’s eligibility under an athletic conference’s rules.
2. Whether, under GSC eligibility rules, Boyd was ineligible as a transfer athlete despite the expiration and nonrenewal of his one-year scholarship.
3. Whether an athletic conference could avoid judicial review of its eligibility determination based on association autonomy where the affected athlete was not a member of the conference.

## Decision

- The Alabama Supreme Court affirmed the circuit court’s declaratory judgment.
- The Court held the eligibility dispute was a proper subject for declaratory relief because it involved a real controversy over the application of binding conference rules to Boyd’s ability to participate at TSU.
- The Court agreed that, applying the undisputed facts to the GSC rules, Boyd was eligible to participate in varsity football at TSU.
- The declaration of eligibility was subject to Boyd being a student in good standing and enrolled at TSU’s Troy campus for the relevant term.

## Legal Principles

- Courts may grant declaratory relief to resolve a present controversy over an athlete’s eligibility when an athletic conference’s rules effectively determine access to participation at a member institution.
- A one-year athletic scholarship that has been fully performed and is not accepted for renewal creates no continuing contractual obligation after its term ends.
- Conference eligibility rules are interpreted according to their text and apparent purpose; where an athlete’s prior scholarship relationship has ended, transfer restrictions aimed at preventing opportunistic switching may not apply.
- Association autonomy arguments carry less force when the person affected by the rules is not a member of the association and seeks review of whether the association applied its own rules consistently.

## Conclusion

The Alabama Supreme Court upheld a declaratory judgment that Boyd was eligible to play varsity football at TSU because the dispute was justiciable and, under the GSC’s rules as applied to the undisputed facts, Boyd’s expired and unaccepted one-year scholarship at Livingston did not render him an ineligible transfer.


Gulf S. Conf. v. Boyd, 369 So. 2d 553 (Ala. 1979)