## Facts

- Nicholas Knapp, a highly recruited high school basketball player, suffered sudden cardiac arrest during a basketball game and was diagnosed with ventricular fibrillation.
- Physicians implanted an internal cardioverter-defibrillator to respond to potentially lethal arrhythmias.
- Northwestern University honored its athletic scholarship commitment to Knapp, and he enrolled receiving scholarship benefits.
- Northwestern’s team physician reviewed Knapp’s medical history, medical literature and guidelines, and other physicians’ recommendations and concluded Knapp was medically ineligible to play intercollegiate basketball due to an unacceptably high risk of serious harm or death.
- Northwestern and the Big Ten Conference declared Knapp permanently medically ineligible to practice or compete, though he remained on scholarship and could engage in other physical activity outside varsity participation.
- Knapp, his family, and supporting physicians believed he could play; Knapp offered measures such as monitoring and liability waivers, and he was willing to assume the risk.
- Knapp sued under § 504 of the Rehabilitation Act seeking an injunction to permit him to play; the district court granted injunctive relief, and Northwestern appealed.

## Issues

1. Whether Knapp was a “qualified individual with a disability” under § 504—i.e., “otherwise qualified” to play intercollegiate basketball despite his cardiac condition.
2. Whether Northwestern’s exclusion of Knapp from varsity basketball constituted discrimination “solely by reason of” disability, or a permissible safety-based eligibility decision grounded in individualized medical judgment.
3. Whether proposed accommodations (e.g., warnings, monitoring, waivers) would reasonably reduce the risk to an acceptable level without fundamentally altering the program.

## Decision

- The Seventh Circuit reversed the injunction and entered judgment for Northwestern and its athletic director.
- The court held Northwestern did not violate § 504 because Knapp was not “otherwise qualified” to participate in intercollegiate basketball.
- Based on credible medical evidence, allowing Knapp to play would pose a significant risk of catastrophic harm that reasonable accommodation could not sufficiently reduce.
- Knapp’s willingness to assume the risk and offer waivers did not obligate Northwestern to sponsor his participation in a program requiring medical clearance and institutional responsibility for athlete safety.
- The Supreme Court denied certiorari.

## Legal Principles

- § 504 protects individuals with disabilities from exclusion “solely by reason of” disability only if they are “otherwise qualified” for the program.
- A person is not “otherwise qualified” when participation would create a significant risk of serious harm that cannot be eliminated or acceptably reduced through reasonable accommodation.
- Safety-based exclusions must rest on individualized, evidence-based medical assessment rather than generalized fears or stereotypes.
- An institution is not required under § 504 to accept an applicant’s preferred medical opinion over a reasonable, expert-supported institutional judgment about safety in a high-risk activity.
- Proposed accommodations that do not materially reduce the relevant safety risk, or that require fundamental changes to medical-eligibility and safety determinations, need not be adopted.

## Conclusion

The court held that § 504 did not require Northwestern to permit a scholarship athlete with a serious cardiac condition to compete in intercollegiate basketball where individualized medical evidence supported the university’s determination that the risk of catastrophic harm remained unacceptably high despite proposed accommodations.


Knapp v. Nw. Univ., 101 F.3d 473 (7th Cir. 1996), cert. denied, 520 U.S. 1274 (1997)