## Facts

- Texas enacted education reforms including a “no pass, no play” statute, Tex. Educ. Code § 21.920, conditioning participation in school-sponsored extracurricular activities on satisfactory academic performance.
- The statute required suspension from extracurricular participation during the next grading period if, in a prior grading period, a student received a grade below the equivalent of 70/100 in any academic class (with an exemption for mentally retarded students).
- Parents and students sued school districts and state education entities to stop enforcement, alleging the statute violated equal protection and due process under the U.S. Constitution.
- The trial court issued injunctive relief prohibiting enforcement and declared the statute unconstitutional.
- State officials pursued direct appellate review; the Texas Supreme Court stayed the injunction pending expedited consideration.

## Issues

1. Whether conditioning extracurricular eligibility on academic grades burdens a suspect class or a fundamental right, triggering heightened equal protection scrutiny.
2. Whether the statute fails rational-basis review as an arbitrary or unreasonable classification.
3. Whether students have a constitutionally protected property or liberty interest in extracurricular participation requiring substantive or procedural due process protections.

## Decision

- The Texas Supreme Court reversed the trial court’s judgment and dissolved the injunction.
- The Court held the statute does not implicate a suspect class or fundamental right; rational-basis review applies.
- The Court held students have no constitutionally protected property or liberty interest in participating in extracurricular activities.
- The Court upheld the statute as rationally related to legitimate state goals of improving academic performance and prioritizing academics over extracurricular participation.

## Legal Principles

- Equal protection challenges to school eligibility rules receive rational-basis review unless they classify by a suspect category or burden a fundamental right.
- Participation in extracurricular or interscholastic activities is not, by itself, a federally or state constitutionally protected property or liberty interest.
- Under rational-basis review, courts uphold legislative education policy choices if the classification is reasonably related to a legitimate governmental interest, even if the policy is contested as unwise.
- When no protected interest is implicated, due process does not require individualized hearings before enforcing an automatic extracurricular ineligibility rule tied to grades.

## Conclusion

The court upheld Texas’s “no pass, no play” statute, ruling that extracurricular participation is not a protected constitutional entitlement and that conditioning eligibility on minimum academic performance is a rational means of advancing the state’s educational objectives.


Spring Branch Indep. Sch. Dist. v. Stamos, 695 S.W.2d 556 (Tex. 1985)