GEORGIA HS ASSN v. WADDELL
248 Ga. 542, 285 S.E.2d 7 (1981)
Case Brief
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GEORGIA HS ASSN v. WADDELL
• PURPOSE: Some disputes are not legal
disputes because no legally cognizable
right is involved in the dispute.
Copyright 2007 Thomson Delmar Learning.
All Rights Reserved.
GEORGIA HS ASSN v. WADDELL
• CAUSE OF ACTION: Suit for equitable
relief grounded in denial of due process
and equal protection.
Copyright 2007 Thomson Delmar Learning.
All Rights Reserved.
GEORGIA HS ASSN v. WADDELL
• FACTS: Football game between Osborne and
Lithia Springs in which referee assessed a
penalty against Lithia Springs for “roughing the
kicker,” mistakenly giving Osborne a fourth down
instead of a first down. Osborne was forced to
kick and Lithia Springs went on to score and win
the game in the few remaining minutes. Trial
court found a denial of due process and equal
protection, cancelled the final score and set a
new game to begin at the point where the
mistaken call was made.
Copyright 2007 Thomson Delmar Learning.
All Rights Reserved.
GEORGIA HS ASSN v. WADDELL
• ISSUE: Whether a referee’s mistaken call
in a high school football game raises due
process or equal protection issues.
Copyright 2007 Thomson Delmar Learning.
All Rights Reserved.
GEORGIA HS ASSN v. WADDELL
• HOLDING: No. (The court also declared
that courts of equity do not have authority
to review referee’s decisions because they
do not raise judicial controversies.)
Copyright 2007 Thomson Delmar Learning.
All Rights Reserved.
GEORGIA HS ASSN v. WADDELL
• REASONING: A high school football player has
no right to participate in interscholastic sports
and has no protectable property interest which
would give rise to a due process claim.
• Regarding the equal protection argument, the
court reasoned in essence that every decision
discriminates against the loser, but that does not
make it a 14th Amendment equal protection
question.
Copyright 2007 Thomson Delmar Learning.
All Rights Reserved.