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Dennin v. Connecticut Interscholastic Athletic Conference, Inc.

Citations: 94 F.3d 96; 1996 WL 493014Docket: No. 1801, Docket 96-7065

Court: Court of Appeals for the Second Circuit; August 30, 1996; Federal Appellate Court

Narrative Opinion Summary

The case involves an appeal by The Connecticut Interscholastic Athletic Conference, Inc. (CIAC) against a district court ruling which found that CIAC violated the Americans with Disabilities Act (ADA) and the Rehabilitation Act by refusing to waive the maximum-age rule for a 19-year-old high school student with Down Syndrome. The district court had granted a preliminary injunction allowing the student to participate in the swim season, emphasizing the therapeutic benefits and lack of competitive disadvantage. CIAC argued against the applicability of the ADA and Rehabilitation Act to its rules. However, the appeal was dismissed as moot because the swim season ended on March 2, 1996, and the plaintiffs did not seek further relief. The appellate court found no grounds for the 'capable of repetition, yet evading review' exception and vacated the district court's judgment, mandating the complaint's dismissal. This decision underscores the mootness doctrine's application when there is no longer a live controversy and highlights the limits of exceptions to mootness in the absence of a recurring dispute.

Legal Issues Addressed

Americans with Disabilities Act and Rehabilitation Act Applicability

Application: The district court applied the ADA and Rehabilitation Act to CIAC's refusal to waive the age limit for a student with Down Syndrome, finding this refusal constituted discrimination.

Reasoning: The court ordered CIAC to allow David to compete in swim meets for the 1995-1996 season.

Capable of Repetition, Yet Evading Review Exception

Application: The court determined that this exception did not apply as there was no reasonable expectation that the same parties would face the same issue again.

Reasoning: CIAC argues that the case is not moot under the 'capable of repetition, yet evading review' exception, but this exception applies only in exceptional circumstances.

Mootness Doctrine in Appeals

Application: The appellate court dismissed the appeal as moot because the swim season had concluded, and the plaintiffs did not seek further relief, eliminating any continuing controversy.

Reasoning: The appeal is rendered moot as the swim season concluded on March 2, 1996, and plaintiffs stated they would not seek future waivers.

Vacatur of Lower Court Judgment

Application: The appellate court vacated the district court's judgment and instructed dismissal of the complaint as the appeal became moot.

Reasoning: The appellate court is obligated to vacate the lower court's decision and remand the case for dismissal.