Case Analysis: Pryor V. Ncaa, 288 F.3d 548 (3d Cir. 2002)

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Case Description
This case involves the Plaintiff, Kelly Pryor, and the Defendant, National Collegiate Athletic Association, in a complex argument that involves racial discrimination under Title VI and the NCAA adoption of Proposition 16 as well as Americans with Disabilities Act and Rehabilitation claims. The court must carefully consider the claims Pryor has brought forth and determine if the discrimination of Proposition 16 was purposefully adopted by adding certain education requirement to ultimately hinder the amount of scholarships awarded to incoming black student athletes. Throughout this case analysis, I will weigh the different evidence presented from both parties and report the court’s reasoning for decisions made in Pryor v. NCAA. Kelly Pryor is an African American student athlete that was being recruited by NCAA Division-1 institutions to play soccer. Pryor signed a National Letter of Intent to play at San Jose State under an athletic scholarship. After graduating high school, Pryor failed to meet Proposition 16 standards that were listed as part of the NLI but was able to retain her scholarship under the Americans with Disabilities Act because of a learning disability. This allowed Pryor to practice with the team but not compete as a freshman. As a sophomore, Pryor would have full ability to participate if she met other minimum academic requirements. Pryor raises complaint against the NCAA’s decision to adopt Proposition 16 to purposefully improve graduation rates among black student athletes. Proposition 16 is a neutral policy that requires incoming freshman that want to participate in NCAA athletics to maintain certain requirements as a high school graduate. These standards under Proposition 16 include the number of core classes raised from 11 to 13, an additional two elective courses, completion of four years of English compared to three, and a sliding scale for SAT/ACT scores combined with a student’s GPA that follows accordingly, the student-athlete who earns a 2.0 GPA must combine it with a minimum 900 SAT score to be eligible for Division 1 competition. The student-athlete who earns a 2.5 GPA can score 700 and be eligible. The new criteria of Proposition 16 raises argument for the Plaintiff that the NCAA was aware of the effect this Proposition would cause to black student athletes and in fact, intended for it to “screen out” more black students from ever receiving athletic scholarships. The NCAA adopted Proposition 16 to prelude Proposition 48, which was initially created to address the perception that the NCAA was exploiting athletes for their talents with no concern for their education. The Facts and Issues

In February of 2000, Pryor sued the NCAA on claims of Discrimination based on race under Title VI of the Civil Rights Act and 42 U.S.C. 1981. To support this claim, the Plaintiffs often cite to evidence gathered during Cureton v. NCAA. In Cureton, plaintiffs argue that Proposition 16 created disparate impact on racial minorities. The district court concluded that Proposition 16 violated Title VI for minorities but accepted the NCAA’s goal to raise ALL student-athletes graduation rates, however, it rejected Proposition 16 as a legitimate mean to accomplish this goal. The court agreed that Proposition 16 could benefit black athletes by improving the overall graduation rate but also acknowledged it could still impact minority athletes in the front end. The court reversed the initial ruling that Proposition 16 violated Title VI because Title VI did not apply to the NCAA because they did not exercise “controlling authority” over all its members’ decision about student athlete requirements, which the Supreme Court later upheld. The Plaintiff often refers to the Cureton case for evidence but insists that the ultimate ruling of that case is different from their case that is brought forward. The complaint most referred to in Cureton is the “explicit race-based goal of Proposition 16...
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