## Facts

- Muhammad Ali, a former World Heavyweight Boxing Champion, held a New York boxing license from 1961 until April 1967.
- In April 1967, New York’s athletic commission suspended Ali’s license based on his refusal to submit to induction into the U.S. Armed Forces.
- Ali was convicted in federal court for refusing induction and sentenced to five years’ imprisonment; he remained free on bond while appellate proceedings continued.
- Under New York law, Ali’s license automatically expired on September 30, 1967.
- Ali later applied to renew his license; the commission refused solely because of his federal felony conviction, indicating he could reapply if the conviction were overturned.
- Ali brought a § 1983 action seeking declaratory and injunctive relief, alleging constitutional violations; the case proceeded on an equal protection theory.
- Ali presented evidence that the commission had licensed or permitted other boxers with serious criminal records, including violent crimes, to compete in New York.

## Issues

1. Whether denying Ali a boxing license solely due to his federal draft-refusal felony, while allowing other fighters with serious convictions to box, likely violated the Equal Protection Clause under rational-basis review.
2. Whether Ali satisfied the requirements for a preliminary injunction, including likelihood of success and irreparable harm.

## Decision

- The court granted a preliminary injunction restraining the commission and its members from denying Ali a New York boxing license pending final adjudication.
- The court found Ali made a sufficient showing of likely success on his equal protection claim based on apparent disparate treatment not supported by a consistent, rational policy.
- The court found irreparable harm because continued exclusion during Ali’s athletic prime threatened loss of competitive opportunity and earning capacity not readily remedied by damages.
- The balance of equities and public interest favored interim relief absent a record showing Ali posed a safety risk or threatened the integrity of the sport.

## Legal Principles

- Even where participation in a heavily regulated profession is treated as a privilege, state licensing discretion is constrained by the Equal Protection Clause and may not be exercised arbitrarily or discriminatorily.
- Under rational-basis review, a licensing authority must apply disqualifying criteria in a consistent, non-selective manner tied to legitimate regulatory objectives.
- A preliminary injunction may issue where the applicant shows a substantial likelihood of success on the merits and irreparable harm, with equities and public interest supporting interim relief.

## Conclusion

The court preliminarily enjoined New York’s athletic commission from denying Muhammad Ali a boxing license based solely on his draft-refusal conviction, concluding that the preliminary record supported a likely equal protection violation due to selective, inconsistent treatment compared to other convicted fighters and that continued exclusion would cause irreparable harm.


Muhammad Ali v. Div. of State Athletic Comm’n of Dep’t of State of N.Y., 316 F. Supp. 1246 (S.D.N.Y. 1970)