The Rhode Island Interscholastic League (League) is a nonprofit body made up of public, private, and parochial high schools that voluntarily opt into membership. The League supervises and administers athletic programs, contests, and schedules throughout the state. The League has a number of eligibility requirements to ensure fair and equitable play among the member schools. One of these rules is the “Eight-Semester Rule,” which limits student-athletes to four consecutive years of eligibility starting in the ninth grade.
John Doe, a student with multiple psychological and learning disabilities sought a waiver from the League’s “Eight-Semester Rule.” After initially enrolling in a Rhode Island parochial high school in Fall 2020, Doe transferred to an out-of-state boarding school the next year and, on advice from the boarding school’s counselor, repeated ninth grade so that he would have the full four-year experience and to give him more maturity and preparation for the school’s academic rigor. Two years later, he transferred again—this time back to a Rhode Island private school—and by League rules, his eighth semester of eligibility would end at the conclusion of his junior year.
Seeking to continue playing sports during his senior year, Doe and his parents requested a waiver, arguing that his disabilities were the reason he needed to transfer and repeat a grade, and that permitting him to play was a reasonable accommodation under Titles II and III of the Americans with Disabilities Act (ADA).
The League denied the waiver through its multistep administrative process, concluding that the documentation did not show an academic or athletic hardship sufficient to override the rule. The denial was affirmed on appeal within the League’s internal process. Subsequently, Doe sued in federal court, claiming that the refusal to waive the rule constituted unlawful discrimination under the ADA.
The trial court granted Doe’s request for a permanent injunction, reasoning that the League qualified as a public entity under Title II and a place of public accommodation under Title III, and that Doe’s disability was the but-for cause of his ineligibility. The trial court found that the waiver he requested was a reasonable accommodation and concluded that the League had not demonstrated that the Eight-Semester Rule was essential to the League’s athletics program. The League appealed.
To bring a reasonable accommodation claim under Title II or III, there are overlapping requirements under both standards. Both require that a plaintiff show (1) “but for” causation (i.e., that the plaintiff’s disability was the reason for the exclusion by defendant); and (2) that the accommodation sought for the disability was reasonable.
First, the First Circuit Court of Appeals held that Doe’s ineligibility was not caused by his disability but by the family’s decision to reclassify him as a freshman when transferring to the out-of-state school—well before his disability diagnoses. Even though his disability later played a role in his return to Rhode Island, the Court concluded that the student’s eligibility clock had already begun and run out irrespective of his disability. The Court also noted that to hold otherwise would allow a student to circumvent the rules by simply stating that a disability was their motivation to participate, even if their eligibility bears no relationship to the disability. Therefore, the Court found no causal link between the disability and the ineligibility under the ADA’s “but-for” standard.
Second, the Court held that granting the waiver would fundamentally alter the nature of the League’s athletics program. The Eight-Semester Rule, the Court explained, is integral to the League’s mission of promoting fairness, broad participation, and competitive parity. Allowing one student to play beyond the rule’s limits, especially after already playing eight semesters, would create an unfair advantage and potentially displace other students. The Court noted that in the past decade, the League had never granted a waiver to permit participation beyond eight semesters, and that waivers were only issued when students missed prior semesters entirely due to extraordinary circumstances such as homelessness or severe mental health crises.
Drawing on precedent from other circuit courts of appeal and referencing guidance from the National Federation of State High School Associations, the Court concluded that the League’s policy was neutral, evenly applied, and closely tied to its educational and participatory goals. As such, requiring the League to waive the rule under these circumstances would not be a reasonable accommodation—it would be a fundamental alteration prohibited under both Titles II and III of the ADA.
Doe v. R.I. Interscholastic League (1st Cir. 2025) 2025 U.S. App. LEXIS 11939
Note: LCW covered this case previously. This case is a good reminder that, while schools must reasonably accommodate students with disabilities under the ADA, they are not required to fundamentally alter their programs.