In a decision issued on April 8, 2025, the Wisconsin Supreme Court reversed the Court of Appeals’ ruling in favor of high school wrestler Hayden Halter, upholding the Wisconsin Interscholastic Athletic Association’s (WIAA) interpretation and application of its suspension rules.
Background
In February 2019, Hayden Halter, a sophomore wrestler at Waterford Union High School, was ejected from a varsity wrestling meet due to two unsportsmanlike conduct violations. According to WIAA’s rules at the time, such an ejection required the athlete to serve a suspension during the “next competitive event.” Halter attempted to serve this suspension by sitting out a junior varsity meet before the regional tournament. However, the WIAA determined that this did not satisfy the suspension requirement, asserting that the “next competitive event” referred to the next varsity-level competition, which was the regional tournament.
Halter and his father filed a civil action to prevent the WIAA from barring him from postseason competition. The circuit court issued a temporary restraining order, allowing Halter to compete, and he went on to win the state championship. The circuit court later ruled in favor of the WIAA, but the Court of Appeals reversed this decision, concluding that (1) the WIAA is a state actor under the Supreme Court’s Brentwood standard and (2) the WIAA acted arbitrarily in interpreting and applying its Rules of Eligibility.
Supreme Court’s Decision
After granting the WIAA’s petition for review, the Wisconsin Supreme Court reversed the Court of Appeals’ ruling. The majority concluded that even under certiorari review, the WIAA acted within reason in applying its interpretation of the suspension rule. The Court emphasized the WIAA’s longstanding published guidance, including examples showing that suspensions for varsity-level conduct must be served at the next varsity event—not a lower-level competition. The Court also highlighted that the rules and interpretations had been clearly communicated to schools prior to the postseason.
Importantly, the Court declined to rule on whether the WIAA is a state actor under the Brentwood “substantial entwinement” standard, avoiding a potentially precedent-setting constitutional question. While the question was answered in the affirmative by the Court of Appeals in this case, the decision is reversed by the Supreme Court, even though it did not address the issue. The Supreme Court also did not decide whether WIAA decisions are generally subject to certiorari review, assuming for purposes of the opinion that they were—and still siding with the Association.
A dissent by Chief Justice Annette Ziegler criticized the majority for deferring to the WIAA’s interpretations, arguing they lacked consistency and transparency. Most important to her dissent, the Chief Justice argued that the majority opinion failed to meaningfully develop the law or answer questions that have statewide importance.
While the WIAA’s status as a state actor under the Brentwood standard has evaded judicial review for more than two decades (aside from the now overruled decision from the Court of Appeals), the Wisconsin Supreme Court missed an opportunity to address the question and provide meaningful guidance to lower courts in future cases between Wisconsin high school athletes and the WIAA.
Implications
This decision represents a major win for the WIAA, reaffirming its authority to interpret its own eligibility rules and apply them in ways courts will typically not second guess, provided they act reasonably and within published guidance. Further, this ruling underscores the deference courts may give to athletic associations like the WIAA in interpreting their own rules, provided their decisions are reasonable and not arbitrary. It also clarifies that under certiorari review, courts will not substitute their judgment for that of the organization unless there is a clear abuse of discretion.
For student-athletes and WIAA member schools, this decision highlights the importance of understanding and adhering to the interpretations and applications of rules by governing bodies like the WIAA. It also illustrates the challenges in seeking judicial relief against such organizations’ decisions. With the state Supreme Court declining to provide clarity on the WIAA’s status as a state actor, it remains unclear whether high school student-athletes in Wisconsin are entitled to the constitutional protections (e.g., freedom of speech and due process) afforded to individuals that are regulated by state actors.
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