Larry E. Wright v. Arkansas Activities Association (Aaa)

MEHAFFY, Chief Judge

(dissenting).

In April 1973 the Blytheville, Arkansas School District offered plaintiff a one-year contract of reemployment as head football coach at Blytheville High School. Plaintiff accepted this offer. At approximately this same point in time the defendant Arkansas Activities Association was conducting an investigation into charges that the Blytheville School District, through the actions of plaintiff, had violated certain association rules. On June 22, 1973 the association executive committee conducted a hearing regarding the charges. Although four representatives of the *30school district were present at this hearing, plaintiff apparently declined to attend. At the conclusion of the hearing the association executive committee placed the Blytheville High School on probation for one year and ordered that:

Coach Larry Wright [be] suspended from coaching at any member school for one year because in the opinion of the Executive Committee he knowingly violated AAA regulations pertaining to football practice.

Four days later the Blytheville School District requested the defendant association to conduct a second hearing to enable the plaintiff and the district to present certain additional evidence. On July 5th the association executive committee agreed to rehear the matter. Proceedings in the district court were stayed pending the association rehearing. The second AAA hearing was held on July 13, 1973. Plaintiff attended this hearing with retained counsel, as did representatives of the Blytheville School District. After considering extensive testimony from some twenty witnesses, the association executive committee unanimously concluded that its out-of-season rules for football had been violated by plaintiff’s conduct and ordered that:

•x- * * the Blytheville School District be placed on one year probation and that Blytheville High School may not participate in football games with teams of other members of A.A.A. for a period of one year if such Blythe-ville High School team is coached by Coach Larry Wright.

In response to the association’s investigation and ultimate order the school district reluctantly requested plaintiff’s resignation and offered plaintiff instead a one-year contract as teacher at a substantially reduced salary. Plaintiff agreed to submit his resignation and accept the substitute contract, subject of course to the outcome of this litigation.

Against this factual background the district court concluded that all procedural requirements of the due process clause had been satisfied by the AAA, but that the conditional portion of the association executive committee’s revised order violated plaintiff’s substantive due process rights. The district court sustained the revised order insofar as it placed the Blytheville School District on probation, but the court ordered the AAA to rescind that portion of the order that offered the school district a partial reprieve on condition that it forego the football coaching services of plaintiff for one year.

If this case involved the validity of the defendant association’s first order, I might well be able to concur in the result reached by the district court and the majority. The original executive committee order purported to terminate plaintiff’s existing contract and to impair substantially plaintiff’s ability, at least for one year, to pursue his chosen profession. I believe there is substantial doubt that the defendant association could, within the limits of due process, take such drastic, direct, and unilateral action against the property interests of a non-member of the association without some basis of authority in the association rules.

I am convinced, however, that the association’s revised order, which is the only action in question before us, presents significantly different constitutional considerations. The revised order directly affected only the Blytheville School District, an association member. The nature of the order, to the degree it affected the association member, was clearly authorized by the discretionary sanctioning power expressly vested in the association executive committee by the AAA rules. The second hearing held by the AAA to reconsider its original order was full, fair, and could hardly be viewed as a sham to cure any prior procedural inadequacies. Finally, and most importantly, there was nothing in the revised AAA order that altered plaintiff’s existing contract rights visa-vis his employer or directly impaired his ability to pursue his chosen profession.

*31I realize, of course, that the executive committee’s revised order did place the school district on a painful election of either terminating plaintiff’s existing contract or foregoing the AAA football competition of one of its schools for one year. In facing this option, however, the school district was confined by the contractual obligations it had already made to plaintiff. Thus, if plaintiff’s violation of AAA rules did not constitute grounds for modification or termination of his contract by the school district, the school district would be in no position to unilaterally satisfy the conditional aspect of the executive committee’s order. If, on the other hand, the school district had made compliance with AAA rules a condition of plaintiff’s contract, then he would be in no position to claim inadequate or unfair notice.

The majority opinion suggests that the due process restrictions on the AAA reach beyond direct and unilateral deprivation of plaintiff’s property rights to include any “wrongful interference with Wright’s coaching contract.” Interference by a third party with the contractual relations between others has, of course, been recognized for many years as a basis in tort law for granting damages and injunctive relief. See, e. g., W. Prosser, Torts § 123 (3rd ed. 1964); Restatement of Torts § 766 (1939). Assuming for purposes of argument that the due process clause, by some analogy to tort law, does confer a federal constitutional right to be free from all state action that could interfere unduly with contractual relationships, I cannot agree that plaintiff is entitled to relief in this case.

There is no doubt that the AAA order in question indirectly, but nonetheless substantially, modified plaintiff’s employment relationship. Claims for tor-tious interference with contractual relationships, however, have always been subject to the defense of justification or, in the language of the Restatement, “privilege.” I am firmly convinced that the AAA’s order was justified even though it may have amounted to a significant practical impairment of plaintiff’s relationship with the Blytheville School District. It is undisputed that the association executive committee could properly have ordered a suspension of all Blytheville School District participation in AAA athletic competition as a sanction for its violation of association rules. Such a sanction, however, would have punished severely the students and other participants in AAA activities who were entirely innocent of the wrongdoing. The sanction ultimately selected by the association was one that was not only authorized by the AAA rules, but also was drawn as narrowly as possible to punish only those primarily responsible for the rule violation. Indeed, I cannot imagine a sanction more suitably fitted to the dual purpose of protecting the integrity of the admittedly valid association off-season practice rules while limiting the impact of the punishment to those primarily culpable in their conduct.

I respectfully dissent.