The National College Athletic Association has rejected a proposed civil rights class-action lawsuit that alleged its academic eligibility requirements for Division I sports discriminated against student-athletes at historically black colleges and universities .
Plaintiff Troyce Manassa attended and played men’s basketball for Savannah State University in Georgia. He alleged he was injured when the team was banned from postseason play for the 2016-17 season, per NCAA rules.
The complaint alleged that the NCAA intentionally discriminated against Black student-athletes of HBCUs from DI teams by adopting and enforcing the Academic Performance Program in violation of 42 USC 1981, and that the NCAA conspired to interfere with Manassa’s civil rights by violation of Section 1985. Through the program, an HBCU team is 43 times more likely to receive a ban from postseason competition than a team from a predominantly white institution, according to the complaint.
Manassa’s claims piled up on April 26, 2016, when he learned his team would not be allowed to play in the 2016-17 playoffs, Judge Richard L. Young of the U.S. District Court ruled Thursday southern Indiana.
The court rejected Manassa’s argument that the claims piled up in October 2020, when he first became aware that the NCAA had discriminated against him. “A plaintiff’s cause of action accrues when he discovers he was injured, not when he determines the injury was unlawful,” Young said: quoting an opinion from the Seventh Circuit.
Because the complaint was filed on Dec. 10, 2020, it was outside the four-year deadline for filing a claim in 1981 and the two-year deadline for filing a claim in 1985, Young said.
Manassa also lacks standing to file a class action for a possible injunction because he graduated in 2017 and “will never again be subject to NCAA rules as a student-athlete.” , Young said.
The complaint alleged that the formula on which the Academic Performance Program is based includes measures that the NCAA knew would discriminate against Black student-athletes at HBCUs.
The NCAA chose to rely on graduation statistics even though it knew that rates for black student-athletes were 20 to 30 percent lower than those for white student-athletes, the complaint alleges.
While only 6.5 percent of NCAA Division I schools are HBCUs, 72 percent of teams that have been banned from postseason competition since 2010 have come from HBCUs, according to the complaint.
Rileycate LLC, FeganScott and May Jung LLP represent the plaintiffs. Barnes & Thornburg LLP represents the NCAA.
The case is Manassa v. Nat’l Coll. Athletic assSD Ind., n° 20-cv-03172, 10/19/23.
