Suzanne Leigh Brown, as mother and next friend of Tucker Brown, a minor, v. Oklahoma Secondary School Activities Association

Summary

The Supreme Court of Oklahoma vacated a temporary injunction that barred the Oklahoma Secondary School Activities Association from suspending a high school football player from playoff games. The court held that the Association reasonably construed and applied its fighting rule in good faith and that judicial intervention in the affairs of a voluntary association was unwarranted absent arbitrary, capricious, fraudulent, collusive, or unreasonable conduct.

Holdings

1. Courts may not interfere with a voluntary association's enforcement of its rules absent fraud, collusion, unreasonableness, arbitrariness, capriciousness, illegality, or bad faith. The Association's proceedings and discipline were reasonable, lawful, and undertaken in good faith.
2. The Association reasonably construed Rule 4(b) to define Brown's kick toward an opponent as fighting and to require the resulting two-game suspension to be served in the next playoff games.
3. The district court abused its discretion by granting the temporary injunction because Brown did not establish entitlement to injunctive relief against the Association's reasonable and good-faith enforcement of Rule 4(b).

Questions Presented

1. Whether the district court abused its discretion by granting a temporary injunction against enforcement of the Oklahoma Secondary School Activities Association's suspension of Brown.
2. Whether the Association reasonably construed Rule 4(b) to require the suspension to be served in the next two playoff games rather than in the following regular season.
3. Whether the Association acted arbitrarily or capriciously in enforcing its rules and postponing the playoff games while the injunction was in effect.

Disposition

vacated