[2] While the Supreme Court would reconsider this same case in the future, this specific decision became important in articulating a new principle of what entities are bound by the First Amendment.

[3][4] The association's role in regulating interscholastic competition in public schools was recognized by the state's Board of Education in the case.

[6] The school asserted that their due process rights had been violated because there were no evidentiary hearings to determine the validity of the claim that they inappropriately recruited football players.

In July 1998, the District Court agreed with this argument and granted summary judgement to the Academy, while enjoining the association from enforcing the rule.

[13] Therefore, Souter concluded, the restrictions on denial of due process would apply to the association, and the lawsuit could proceed in the lower courts.

He criticized the usage of a new "entwinement" standard for determining state action, which he said "stretched the doctrine beyond its permissible limits.

The case was sent back to the Sixth Circuit Court of Appeals who instructed the association that they could prevail if they showed the enforced rule was narrowly defined to promote "governmental interests".

[19] In a unanimous decision, Justice John Paul Stevens held that the actual rule did not violate the First Amendment and that the tactics used to recruit football players rose to the level of a governmental interest.