Case Analysis: Pryor V. Ncaa, 288 F.3d 548 (3d Cir. 2002)

Case Description This case involves the Plaintiff, Kelly Pryor, and the Defendant, National Collegiate Athletic Association, in a complex argument that involves racial discrimination under Title VI and the NCAA adoption of Proposition 16 as well as Americans with Disabilities Act and Rehabilitation claims. The court must carefully consider the claims Pryor has brought forth and determine if the discrimination of Proposition 16 was purposefully adopted by adding certain education requirement to ultimately hinder the amount of scholarships awarded to incoming black student athletes.

Throughout this case analysis, I will weigh the different evidence presented from both parties and report the court’s reasoning for decisions made in Pryor v. NCAA. Kelly Pryor is an African American student athlete that was being recruited by NCAA Division-1 institutions to play soccer. Pryor signed a National Letter of Intent to play at San Jose State under an athletic scholarship. After graduating high school, Pryor failed to meet Proposition 16 standards that were listed as part of the NLI but was able to retain her scholarship under the Americans with Disabilities Act because of a learning disability.

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This allowed Pryor to practice with the team but not compete as a freshman. As a sophomore, Pryor would have full ability to participate if she met other minimum academic requirements. Pryor raises complaint against the NCAA’s decision to adopt Proposition 16 to purposefully improve graduation rates among black student athletes. Proposition 16 is a neutral policy that requires incoming freshman that want to participate in NCAA athletics to maintain certain requirements as a high school graduate.

These standards under Proposition 16 include the number of core classes raised from 11 to 13, an additional two elective courses, completion of four years of English compared to three, and a sliding scale for SAT/ACT scores combined with a student’s GPA that follows accordingly, the student-athlete who earns a 2. 0 GPA must combine it with a minimum 900 SAT score to be eligible for Division 1 competition. The student-athlete who earns a 2. 5 GPA can score 700 and be eligible.

The new criteria of Proposition 16 raises argument for the Plaintiff that the NCAA was aware of the effect this Proposition would cause to black student athletes and in fact, intended for it to “screen out” more black students from ever receiving athletic scholarships. The NCAA adopted Proposition 16 to prelude Proposition 48, which was initially created to address the perception that the NCAA was exploiting athletes for their talents with no concern for their education. The Facts and Issues In February of 2000, Pryor sued the NCAA on claims of Discrimination based on race under Title VI of the Civil Rights Act and 42 U.

S. C. 1981. To support this claim, the Plaintiffs often cite to evidence gathered during Cureton v. NCAA. In Cureton, plaintiffs argue that Proposition 16 created disparate impact on racial minorities. The district court concluded that Proposition 16 violated Title VI for minorities but accepted the NCAA’s goal to raise ALL student-athletes graduation rates, however, it rejected Proposition 16 as a legitimate mean to accomplish this goal. The court agreed that Proposition 16 could benefit black athletes by improving the overall graduation rate but also acknowledged it could still impact minority athletes in the front end.

The court reversed the initial ruling that Proposition 16 violated Title VI because Title VI did not apply to the NCAA because they did not exercise “controlling authority” over all its members’ decision about student athlete requirements, which the Supreme Court later upheld. The Plaintiff often refers to the Cureton case for evidence but insists that the ultimate ruling of that case is different from their case that is brought forward. The complaint most referred to in Cureton is the “explicit race-based goal of Proposition 16 stands in stark contrast to the characterization of it as a facially neutral rule. Plaintiff is also able to supply that the NCAA memorandum in the Cureton case asserts that the NCAA’s Proposition 16 policy has lead to an increase in minority graduation rates and states that no other model could have obtained this goal better than Proposition 16. The Plaintiff attempts to identify Proposition 16 as a result to screen out a greater number of black athletes of receiving athletic scholarships and Pryor uses the NCAA initial research memorandum that Proposition 16 would disproportionately affect black student athletes more than any other group. The Decision

The NCAA moved to dismiss this complaint for summary judgment and the result was that the district court granted this motion. The Rationale The district court’s decision to dismiss this case is based on the Plaintiffs failure to prove theory of purposeful discrimination, which is denied under Alexander v. Sandoval where the Supreme Court ruled that even if a federally funded entity knowingly adopts a policy that creates disparate impact, Title VI still affords no remedy and also because Proposition 16 is a facially neutral policy that happened to create a racially disparate impact, it holds no bearing to Title VI.

The court ultimately found that Proposition 16 was created to improve ALL student athlete graduation rights. As for Pryor’s ADA claim, it too was dismissed because Pryor lacked the standing to remedy her loss of eligibility due to the fact the NCAA may still grant her the relief she seeks. The Appeal The Plaintiff argues that she did not lack remedy to bring her ADA claim because the relief she seeks is different from the NCAA bylaws the court’s decision was made from. Pryor also argues that the court improperly relied on the Cureton case to rule against intentional discrimination claims.

Pryor states that the courts misunderstood her theory of “deliberate indifference” brought on by Proposition 16 rather that her theory was to prove deliberate indifference to her rights under Title VI. She again argues that the evidence brought forth from her previous complaint that the NCAA adopted Proposition 16 to raise graduation rates for black athletes shows evidence that the NCAA took race into account. The Plaintiff raises new argument that the National Letters of Intent she signed, which has contractual agreements of requirements to uphold, is invalid because it is a product of Proposition 16 and intentional discrimination.

The NCAA defends Proposition 16 and the NLI because the policies embody academic standards that are necessary to accomplish legitimate educational objectives. They go on to reiterate Supreme Court rulings that in order to prove purposeful discrimination, one must prove racial animus; that is an intention to harm racial minorities. Furthermore, Pryor’s argument of deliberate indifference against Proposition 16 only assumes its own conclusion and does not distinguish itself from that the policy is facially neutral.

NCAA also addresses the Plaintiffs argument of the NLI stating that the NCAA did not deprive her rights of the benefits of the contract rather, the Plaintiff deprived herself by failing to meet the conditions of the contract. The Decision Again, the result ends in a dismissal of charges against discrimination and ADA. The Rationale The courts reference to the Cureton litigation does not appear to cite Cureton for purposes of assessing the truth of the factual allegations in this case, therefore the Plaintiffs arguments hold no weight.

The dismissal of Pryor’s claim under ADA is upheld from the same initial fact that the Plaintiff’s seek of relief lacks redress and is premature because the NCAA may still grant her eligibility. Lastly, as the court did recognize that Proposition 16 did consider race when it adopted the policy, the Supreme Court has made perfectly clear that the consideration of race does not warrant liability for purposeful discrimination. To prove intentional discrimination a plaintiff must be able to show that the NCAA adopted the policy “because of” not in “spite of,” which the Plaintiff is unable to sufficiently prove.

The court was able to show distinction between the “awareness” and its “purpose” as well as see that the Plaintiff’s decision to enter the NLI with agreement to abide by its conditions and receive the benefits of the agreement but by later failing to meet these conditions was at their own fault therefore granting the dismissal of Pryor v NCAA. Related Articles Discrimination-Pryor Notice by John T. Wolohan This article explains the reasoning behind the NCAA adoption of Proposition 16 and how it has pretty much been challenged since day one as a creation to impact the number of black student athletes to receive athletic scholarships.

It goes on to speak about the latest challenge at that time, being Pryor v. NCAA. It hits all the major points such as the National Letter of Intent, Discrimination under Title VI but left out remarks of the ADA claim which also was presented in the lawsuit. It discusses the third courts rulings and how Pryor won that round but not the lawsuit. This article ended by giving What If scenarios and comes to conclusion that the district court’s final ruling was indeed the best outcome for the NCAA and student athletes to keep Proposition 16.

Disparate Impact: Cureton v NCAA and Academic Standards NCAA’s academic standards have survived — for the time being! by Adversity. net This article examines the Cureton case which is the basis for a lot of the arguments brought forth by the Pryor case. It summarizes Proposition 16 and the claims of discrimination to black student athletes. The article explains that plaintiffs believed NCAA’s Division I eligibility requirements disqualified too many incoming black college freshmen whose high school academic performance and SAT scores were below the cutoffs established by the NCAA.

This article was helpful for it included an actual scale that the NCAA uses to determine eligibility, which can be seen at http://www. adversity. net/Disparate_Impact/disparity1. htm. Reclaim Civil Rights: Case Summary of Alexander v. Sandoval This is a brief article to explain why Alexander v. Sandoval makes it much more difficult for victims of discrimination in federally funded programs to justify their rights and was used as reasoning for Pryor v. NCAA. In the Sandoval case, the state of Alabama added an amendment that officially made English the official language.

The Department of Public Safety then issued a rule that the driver’s test would only be provided in English. Sandoval sued over violations of Title VI of the Civil Rights Act of 1964, which prohibits discrimination based on race, color or national origin in federally funded programs. The Supreme Court’s decision that while Title VI does prohibit practices with a discriminatory impact, individuals cannot sue to stop those practices unless they can also show discriminatory intent.

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