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Missouri State High School Activities Association Bylaw 235 is rationally related to the Missouri State High School Activities Association's purpose of drafting rules that protect the welfare of the greatest number of high school athletes possible.
Claire Letendre, a sophomore student, filed suit for injunctive relief to enjoin the Missouri State High School Activities Association (MSHSAA) from enforcing by-law 235, which prohibited students from competing on both a school and a non-school team in the same sport during the school team's season. The trial court denied Claire's request for injunctive relief and dismissed her suit with prejudice. On appeal, Claire claimed that the association's rule violated the Equal Protection clause of the Fourteenth Amendment and her rights of free association under the First Amendment. Moreover, Claim insisted that the prohibition of simultaneous same-sport competition was irrational and unrelated to any legitimate goal of the association.
Could the Association enforce a bylaw prohibiting students from competing on both a school and a non-school team in the same sport during the school team's season?
The appellate court found that its inquiry was confined to whether there was a rational relationship between by-law 235 and any legitimate interest of the association. According to the court, there were reasonable grounds for by-law 235 because a reasonable person could believe that a legitimate goal of the association was furthered by the rule. It was not in the best interest of the majority of high school students to compete in the same sport at the same time on two different teams. The court further held that there was substantial evidence to conclude that the by-law was rationally related to the legitimate goal of protecting the best interest of the larger number of high school students. There was no First Amendment right for a high school student to associate simultaneously with both a school and a non-school swim team.