## Facts

- Kent Conrad Steffes, a minor student-athlete, attended Brentwood School (private) for ninth and tenth grades and participated in cross-country, basketball, and volleyball.
- After sophomore year, Steffes transferred to Palisades High School, the public high school serving his family’s residence.
- The California Interscholastic Federation (CIF) applied its “transfer rule,” which imposes one-year varsity ineligibility for certain transfers, to Steffes.
- CIF declared Steffes ineligible for varsity basketball and volleyball for the 1984–1985 year, though he remained eligible for junior varsity competition.
- Steffes sought a preliminary injunction to prevent enforcement of the transfer rule so he could participate immediately in varsity sports.

## Issues

1. Whether participation in interscholastic athletics is a “fundamental right” under the California Constitution.
2. If not fundamental, whether the CIF transfer rule is constitutionally valid under a deferential equal protection/due process standard requiring a reasonable relationship to legitimate objectives.
3. Whether the trial court abused its discretion in denying preliminary injunctive relief.

## Decision

- The Court of Appeal affirmed the order denying the preliminary injunction.
- The court held participation in interscholastic athletics is not a fundamental right under the California Constitution.
- The court applied rational basis–type review and concluded the transfer rule was reasonably related to legitimate objectives, including discouraging recruiting and maintaining competitive balance.
- Because Steffes did not show a likelihood of success on the merits, the trial court did not abuse its discretion in denying interim relief.

## Legal Principles

- Under California constitutional analysis, strict scrutiny applies only when a challenged rule burdens a right explicitly or implicitly guaranteed by the Constitution or uses a suspect classification.
- Participation in extracurricular activities, including interscholastic athletics, is generally treated as a privilege rather than a constitutional entitlement; it does not constitute a protected property or liberty interest requiring heightened procedural protections.
- Athletic eligibility rules are valid if reasonably related to legitimate purposes, such as preventing recruiting and “school-hopping” for athletic advantage, preserving competitive equity, and supporting the educational purposes of school athletics.
- On appeal from an order granting or denying a preliminary injunction, the reviewing court asks whether the trial court abused its discretion, including consideration of the plaintiff’s likelihood of success on the merits and the balance of harms.

## Conclusion

The court rejected the claim that varsity athletic participation is constitutionally fundamental and upheld the CIF transfer rule as a reasonable, generally applicable eligibility regulation, affirming the denial of a preliminary injunction because Steffes failed to show a probable constitutional violation warranting interim relief.


Steffes v. Cal. Interscholastic Fed'n, 176 Cal. App. 3d 739 (Ct. App. 1986)