## Facts

- Robert L. Parish and other Centenary College basketball players challenged the NCAA’s enforcement of an academic-eligibility bylaw known as the “1.600 Rule.”
- The 1.600 Rule conditioned freshman athletic eligibility on a predictive formula using standardized test scores and high-school standing to project at least a 1.600 college GPA.
- Parish’s ACT scores did not satisfy the NCAA’s predictive threshold, causing many schools to reduce recruitment efforts.
- Centenary (a private college) converted Parish’s ACT scores to SAT equivalents and treated him (and similarly situated players) as meeting its own admission/aid criteria.
- The NCAA determined the conversion practice violated NCAA requirements and adopted a resolution declaring Parish and certain other Centenary players ineligible for NCAA competition.
- The players sued under 42 U.S.C. § 1983, seeking declaratory relief and preliminary and permanent injunctions barring enforcement of the rule and the NCAA’s resolution.
- A temporary restraining order briefly allowed continued play during the season; after an evidentiary hearing, the court ruled on the merits of the requested equitable relief.

## Issues

1. Whether the NCAA’s enforcement of eligibility rules against athletes at a private college constituted “state action” (action under color of state law) sufficient to support Fourteenth Amendment and § 1983 claims.
2. If state action existed, whether the NCAA’s 1.600 Rule violated equal protection such that declaratory and injunctive relief was warranted.
3. Whether plaintiffs showed irreparable harm justifying injunctive relief.

## Decision

- The court held the NCAA’s conduct was not state action and therefore presented no substantial federal constitutional question under § 1983 and the Fourteenth Amendment.
- The court denied declaratory and injunctive relief and dismissed the federal constitutional claims.
- The court further reasoned that participation in intercollegiate athletics is not a constitutional right and that the asserted harms did not warrant federal equitable intervention.
- Even assuming review on the merits, the court found the 1.600 Rule rationally related to the NCAA’s interest in academic standards for student-athletes and declined to override that policy judgment.

## Legal Principles

- Constitutional equal-protection constraints generally apply only to state action; private conduct is not subject to the Fourteenth Amendment absent a sufficient governmental nexus.
- A voluntary private association’s eligibility standards, applied through member institutions’ consensual participation, do not become state action without evidence of state compulsion or comparable governmental involvement.
- Intercollegiate athletic participation, standing alone, is not treated as a fundamental constitutional entitlement triggering heightened constitutional protection.
- Under rational-basis review, academic-eligibility criteria aimed at ensuring student-athlete academic preparedness may be upheld if reasonably related to legitimate objectives.
- Injunctive relief requires a showing of a legally cognizable violation and irreparable injury; disappointment and lost athletic opportunities, without more, are generally insufficient.

## Conclusion

The court refused to treat the NCAA’s enforcement of its academic-eligibility rule against athletes at a private college as state action, rejected the constitutional challenge, and denied declaratory and injunctive relief, leaving the NCAA’s eligibility determination in place.


Parish v. Nat’l Collegiate Athletic Ass’n, 361 F. Supp. 1220 (W.D. La. 1973)