## Facts

- The University Interscholastic League (UIL) ruled that Robstown High School used an ineligible baseball player and ordered Robstown to forfeit all games played with that player, costing Robstown a qualifying district position.
- Parents of eligible Robstown players sued in Nueces County seeking to stop UIL’s enforcement of the forfeiture ruling.
- The Nueces County trial court ordered UIL to hold a playoff game between Robstown and Roma.
- UIL did not schedule the playoff; the Nueces County court held UIL in contempt, declared Roma to have forfeited the unplayed game, and ordered Robstown to advance in the state tournament.
- In separate proceedings, a Travis County court issued orders that protected Roma’s advancement and restrained UIL from forcing Roma to play Robstown, creating conflicting trial-court directives.
- The parents did not dispute the player’s ineligibility; they argued UIL misapplied its own rules and acted arbitrarily by not applying a UIL rule allowing prospective ineligibility in certain late-protest situations.

## Issues

1. Whether the trial court abused its discretion by ordering a specific playoff, holding UIL in contempt for noncompliance, and declaring Robstown the winner of a game that was never played.
2. Whether judicial intervention in UIL eligibility and tournament administration was justified by any violation of a fundamental or constitutional right.
3. Whether UIL was required to apply its internal rule (Section 27) so as to avoid forfeitures, or whether the trial court improperly substituted its interpretation for UIL’s.

## Decision

- The Supreme Court of Texas conditionally granted mandamus relief.
- The Court held the Nueces County trial court abused its discretion by directing tournament scheduling and outcomes, holding UIL in contempt, and awarding a win in an unplayed game.
- The Court concluded that participation in extracurricular athletics is not a fundamental constitutional right and that no constitutional deprivation was shown.
- The Court determined ordinary appeal was inadequate because the tournament was underway and the conflicting orders created immediate, irreparable practical consequences.
- The Court directed the trial court to vacate the playoff order, the contempt order, and the order advancing Robstown.

## Legal Principles

- Mandamus issues when a trial court clearly abuses its discretion and there is no adequate remedy by appeal, including when time-sensitive events would moot effective appellate relief.
- Students have no fundamental constitutional right to participate in extracurricular sports; absent a constitutional or statutory violation, courts should not intervene in eligibility determinations.
- Courts generally may not substitute their judgment for UIL’s interpretation and application of its competition rules unless UIL acts outside its authority or unlawfully.
- A trial court exceeds its authority by managing athletic competition logistics or declaring winners to countermand a governing association’s eligibility ruling.

## Conclusion

The Supreme Court of Texas granted mandamus to stop judicial control of an ongoing UIL tournament, holding that the trial court’s injunction, contempt finding, and declared advancement were an abuse of discretion because no constitutional right to participation was implicated and appellate relief was inadequate given the time-sensitive competition.


In re Univ. Interscholastic League, 20 S.W.3d 690 (Tex. 2000)