## Facts

- John Tiffany attended St. Mary’s High School in Phoenix and sought to compete in interscholastic athletics during the 1983–84 school year.
- Tiffany turned 19 on August 5, 1983, before his senior year began, after being retained in early grades due to a learning disability.
- The Arizona Interscholastic Association, Inc. (AIA) had a bylaw making students ineligible for athletics if they turned 19 before September 1 of the school year.
- AIA bylaws also authorized the Executive Board, in individual cases and in its discretion, to waive or modify any eligibility rule when circumstances beyond the student’s or parent’s control would make enforcement an undue hardship.
- Tiffany requested a hardship waiver; the Executive Board held a hearing and denied it based on a policy of not granting hardship exceptions to the nineteen-year-old rule.
- On appeal, AIA conceded Tiffany’s ineligibility resulted from circumstances beyond his control.

## Issues

1. Whether a student has a Fourteenth Amendment due process right to participate in interscholastic athletics such that denial of a hardship waiver from the nineteen-year-old rule violates due process.
2. Whether AIA acted unlawfully under its governing rules by treating the hardship-waiver provision as unavailable for age-eligibility cases, rather than applying the bylaw’s criteria in an individualized manner.

## Decision

- The court held that participation in interscholastic athletics is not a constitutionally protected property or liberty interest, and denial of a hardship waiver did not violate the Due Process Clause.
- The court held the nineteen-year-old eligibility rule was rationally related to legitimate objectives such as safety and fair competition.
- The court agreed, however, that AIA acted unlawfully by failing to follow its own bylaws when it denied the waiver based on a categorical no-waiver policy for age cases.
- The court affirmed in part and reversed in part, rejecting the due process claim but sustaining the ruling that AIA must act consistently with its bylaws in processing hardship requests.

## Legal Principles

- High school students have no constitutional entitlement to participate in interscholastic athletics; exclusion under a neutral eligibility rule generally does not implicate Fourteenth Amendment due process.
- Age-eligibility limits for scholastic sports are permissible when rationally related to legitimate purposes, including safety and competitive fairness.
- A voluntary athletic association must follow its own bylaws when exercising discretionary authority, including waiver procedures it has created.
- When bylaws authorize individualized hardship waivers based on defined criteria, decision makers may not adopt a blanket policy that nullifies the waiver process for an entire category of cases.

## Conclusion

The court rejected a constitutional due process challenge to an athletic age-eligibility rule, but held the association acted unlawfully by refusing to apply its broadly worded hardship-waiver bylaw on a case-by-case basis and instead relying on a categorical no-waiver policy for age-ineligibility.


Tiffany v. Ariz. Interscholastic Ass’n, Inc., 151 Ariz. 134, 726 P.2d 231 (Ct. App. 1986)