Louisiana High School Athletics Ass'n v. State

Summary

The Louisiana Supreme Court reviews a constitutional challenge brought by the Louisiana High School Athletic Association against Louisiana statutes regulating athletic eligibility and auditing. The court affirms the determination that the Title 17 statutes are unconstitutional special laws under the Louisiana Constitution. It reverses the ruling concerning the Title 24 statutes, holding that the LHSAA is not a statutory quasi-public body and that the audit provisions violate equal protection.

Holdings

1. La. R.S. 17:176(F), 17:176(G), and 17:236.3 are unconstitutional under La. Const. art. III, § 12(A)(7) because they are special laws that amend or explain the charter and bylaws of the privately formed LHSAA.
2. La. R.S. 24:513(A)(1)(b)(v) does not apply to the LHSAA because the LHSAA is not subject to the Open Meetings Law and therefore cannot satisfy the statutory definition of a quasi-public agency or body.
3. La. R.S. 24:513(J)(4)(a) and (b) are unconstitutional under the Equal Protection Clause because they single out the LHSAA based on BESE's adoption of its scholastic rules and are not rationally related to a legitimate state interest.

Questions Presented

1. Whether La. R.S. 17:176(F), 17:176(G), and 17:236.3 are prohibited special laws that amend, renew, extend, or explain the charter of a private corporation in violation of La. Const. art. III, § 12(A)(7).
2. Whether the LHSAA is a quasi-public agency or body subject to La. R.S. 24:513(A)(1)(b)(v) because it is subject to the Open Meetings Law and receives income from a public agency or body.
3. Whether La. R.S. 24:513(J)(4)(a) and (b), which impose audit-filing and potential audit obligations on entities whose scholastic rules are adopted by BESE, violate equal protection.
4. Whether the Supreme Court's prior decision in Spain v. Louisiana High School Athletic Association should be overruled.

Disposition

reversed