Zavior Ward v. Interscholastic League of Honolulu, et al.

Summary

The United States District Court for the District of Hawai‘i denied the Interscholastic League of Honolulu’s motion for judgment on the pleadings in Zavior Ward’s procedural due process action. The court held that it was premature to decide, without further factual development, whether Ward had a constitutionally protected property interest in participating in interscholastic athletics under Hawai‘i or federal law. The court also denied Hawaii Baptist Academy’s motion to join the motion as moot.

Holdings

1. ILH was not entitled to judgment on the pleadings because the pleadings did not clearly establish that Ward lacked a constitutionally protected property interest in participating in interscholastic athletics.
2. The existence of a property interest in interscholastic athletics could not be resolved as a matter of law at the pleading stage; discovery and further factual development were necessary.

Questions Presented

1. Whether ILH was entitled to judgment on the pleadings on Ward's procedural due process claims because Ward could not possess a constitutionally protected property interest in participation in interscholastic athletics.
2. Whether the asserted property interest could be resolved on the pleadings without factual development concerning statutes, regulations, contracts, established practices, and modern developments in interscholastic athletics.

Disposition

other