A few years ago, a parent in Massachusetts was convicted of assault after he had attacked his son’s youth hockey coach. In 2011, parents got involved in a fistfight in Columbus, Ga., just after a Little League baseball game. And in an incident in Hoover, Ala., about a decade ago parents of Grissom High School boys soccer players confronted a referee after a state tournament match and threw chairs at him.
Everyone who has had children in youth sports has stories about unruly parents screaming and yelling at coaches, officials and players. Media outlets routinely report on instances of parental misconduct involving athletic contests their children are involved in.
High school coaches report that one of the more difficult aspects of their jobs involves having to deal with parents who are not happy with how young Johnny or Jane is being used during games and about playing time. Most people simply resign themselves to the fact that over-the-top parents are just a part of youth sports.
However, a recent court case suggests that school and youth sports administrators may have the power to curtail this kind of behavior. The Third Circuit Court of Appeals affirmed a federal district court ruling Jan. 30 in a case involving the parent of two high school basketball players. This case arose at a high school in Pen Argyle, Pa.
The appeals court ruled that a school district was within its rights to ban a parent from attending a home game, who violated the district’s guidelines “by using incendiary language denigrating coaches and young players.” The Court upheld the decision by administrators in the Pen Argyle Area School District to ban William Blasi from attending basketball games at the school.
Blasi has twin boys whom he describes as being mixed race—part white and part Chinese. They both had tried out and made the basketball team at their high school. Neither of them had been playing much. Thisthis did not sit well with their father.
Blasi, a pro se litigant, sued the district after the defendant’s coaches “encouraged assaults on his children by other children who ‘were mainly white,’ and denied his sons equal opportunity to play basketball because ‘lesser skilled white boys’ and ‘much lesser skilled white boys’ played more than his sons.”
Blasi sent school officials 17 emails in which he complained about how the program was run and attacked the actions and motives of the coach and other school officials. He also accused these officials of being racially biased towards his sons by treating them differently and more harshly than white players.
In 2005, the school district had adopted guidelines for parental/spectator conduct with respect to school sports activities. Blasi did not deny that he was aware of the guidelines. He challenged the school principal’s decision by arguing that his basic constitutional rights were being violated.
Blasi alleged in his lawsuit that the action taken against him was a violation of his First Amendment right to freedom of expression, his right to petition the government for redress, and his right to be free from retaliation for exercising his constitutional rights.
The school district successfully moved to dismiss the complaint, pursuant to Rule 12(b)(6) of the Federal Rules of Civil Procedure, leading to the appeal. The appeals court ruling upheld the action of the trial judge in dismissing the lawsuit. The Court cited several cases as precedent for the proposition that school officials have a right to ensure a safe educational environment for students and that this need to maintain order superseded any alleged freedom of speech rights Blasi claimed.
The majority opinion issued by the Court stated in part, “The narrower goals of an athletic team differ from those of academic pursuits and are not always consistent with the freewheeling exchange of views that might be appropriate in a classroom debate. See, e.g., Lowery v. Euverard, 497 F.3d 584 (6th Cir. 2007).
“School officials have a legitimate interest in affording student athletes ‘an educational environment conducive to learning team unity and sportsmanship and free from disruptions that could hurt or stray the cohesiveness of the team.’” Wildman v. Marshalltown Sch. Dist., 249 F.3d 768, 771 (8th Cir. 2001).
There are other cases that have been decided in recent years that assert that a school district’s need to achieve an effective and efficient (i.e., orderly) athletic program for students who choose to play allows schools to condition participation on the acceptance by students and parents of some limitation on certain constitutional rights.
Courts have ruled that this principle allows governing bodies over high school sports to impose limits on the recruitment of student-athletes. Courts have noted that participation in sports as an extra-curricular activity is a choice. That means it is a privilege and not a right. As such, participants should expect that there will be some rules that might infringe on normal rights.
This case is important because no one accused Blasi of being unruly or disruptive at a game. He was accused of violating guidelines that he had agreed to by challenging the authority and integrity of the coaching staff. In plain language, the Court ruled that organizing bodies for youth sports do have the right to demand that parents follow certain rules. Freedom of speech is not so sacrosanct that it cannot be regulated in a reasonable manner.
The Court cited another case where a court held that “Athletic programs may…produce long-term benefits by distilling positive character traits in the players. However, the immediate goal of an athletic team is to win the game, and the coach determines how best to obtain that goal….The plays and strategies are seldom up for debate. Execution of the coach’s will is paramount.” Lowery v. Euverard, 497 F3d. 584, 589 (6th Cir. 2007).
The Court held that by using incendiary language to attack both the coaches and other players, Blasi had jeopardized the interests of other participants in the basketball program.
Anyone working in a leadership capacity with respect to youth sports should be aware of this case. It is an important precedent in establishing limits on how and when a parent can express dissatisfaction with players and coaches. Parents should let their kids play and confine themselves to watching and supporting their sons and daughters.
Readers can find this case online by entering the case citation as an Internet search. The full citation is: William Blasi v. Pen Argyl Area School District; 3rd. Cir.; No. 11-3982, 2013 U.S. App. LEXIS 2095; 1/30/13.
Greg Tyler is the Library Director at the United States Sports Academy. He has also taught courses at the Academy in sports law. He worked for years in youth sports as a coach, league administrator and as a soccer referee. He has a law degree and practiced law for a number of years. You can reach him at gtyler@ussa.edu.