NIVÔSE, 185

FIFTH COURT OF APPEALS OF THE L’NHRAEI COMMONWEALTH OF PLANETS

K’CH’TLL’K
v
COMMONWEALTH ASSOCIATION FOOTBALL LEAGUE, INC,
SEAN COHEN,
NEW PROVIDENCE BLAZE FOOTBALL CLUB,
and PHILIP RUIZ

APPEALED FROM THE SUPREME COURT OF 36 URSAE MAJORIS III

Number 185-24

Argued 12 Brumaire 185 – Decided 4 Nivôse 185

JUSTICE LLOYD delivered the opinion of the court, joined by JUSTICE T’MIRAEL and JUSTICE SPENCER.

The matter in this case concerns two issues: the application of the Anti-Discrimination Act (ADA)1 passed by the legislature of 36 Ursae Majoris III in 182 and whether that law is constitutional under the constitutions of 36 Ursae Majoris III and the L’nhraei Commonwealth of Planets.

I

The defendant COMMONWEALTH ASSOCIATION FOOTBALL LEAGUE, INC (CAFL) is a corporation founded in 72. It consists of 24 separately owned, franchised association football (soccer) teams in two divisions, including defendant NEW PROVIDENCE BLAZE FOOTBALL CLUB which is owned by defendant PHILIP RUIZ, in two divisions. CAFL organises and conducts a season of 88 games, followed by a post-season tournament between the 8 teams in each division which won the most games. Defendant SEAN COHEN is the Commissioner of the CAFL, a position which oversees the operation of the entire league. The office of the Commissioner is the final judge on all matters concerning the league, including the addition of teams, suspension of players, and interpretation of the rules of football within the CAFL. Revenues from admission to football games, broadcast rights to these games, and selling of related merchandise amounted to approximately £24 million in 184.

New players enter the CAFL in three ways. Each year, representatives of each CAFL team view a large number of football matches held by schools and various amateur leagues. The best players on these teams are often invited to sign employment contracts with a CAFL team. Other players enter a draft, in which each team in turn selects a player from among those entered in the draft. In addition, during Germinal of each year, each team in the CAFL holds tryouts for the following season. These tryouts are open to all members of the public. No particular level of experience is required in order to participate, although each participant must pay £1 4s which goes to the cost of staging the tryouts.

II

K’CH’TLL’K is a talented athlete. He is also a member of an avian species which calls itself the Evi’ru. He attended New Providence University in new Providence on 36 Ursae Majoris III and played on its championship football team for three years. In 183, K’ch’tll’k was named Most Valuable Player on his team.

K’ch’tll’k, like all Evi’ru, is able to fly with the use of two large wings stretching just above his head sand almost reaching the ground. Also like all Evi’ru, he is unable to walk long distances and cannot run for more than about a minute without experiencing severe pain and the risk of injury to his legs and feet. While attending university, the school made a request supported by detailed medical records to the Commonwealth Collegiate Athletic Association (CCAA) to waive in his case the rule that "A direct free kick is awarded to the opposing team if a player…handles the ball deliberately"2 and, if K’ch’tll’k plays in the position of goalkeeper, to waive the first four offences in the rule that:

An indirect free kick is awarded to the opposing team…if a goalkeeper, within his own penalty area, commits any of the following five offences:

takes more than six seconds while controlling the ball with his hands before releasing it from his possession

touches the ball again with his hands after it has been released from his possession and has not touched any other player

touches the ball with his hands after it has been deliberately kicked to him by a team-mate

touches the ball with his hands after he has received it directly from a throw-in taken by a team-mate,

wastes time3.

Either type of free kick is a penalty shot in which a player is entitled to kick the ball towards the goal. No player on the opposing team may come closer than ten yards to the ball until it is kicked. In a direct free kick, the player may kick the ball into the goal; an indirect kick must first be kicked to another player before a goal is attempted. Approximately seventy percent of such kicks result in a goal, which can often be the difference between a win and a loss4.

In K’ch’tll’k’s specific case, striking the ball with the wings would not be considered handling the ball. He was also allowed to move around the field through the use of flight.

In Germinal of 184, K’ch’tll’k attended an open tryout for the New Providence Blaze. He was informed that, under the rules of the CAFL, flying was prohibited and he would be required to walk and/or run. The rules of football as written by the Fédération Internationale de Football Association, the sport’s internationally-recognised governing body do not prohibit flying. There is an optional appendix to the rules that allows leagues to adopt a rule prohibiting flying, but the rule does not appear in the main portion of the rulebook. K’ch’tll’k filed a claim under the ADA claiming illegal discrimination based both on race and disability.

III

The legislature of 36 Ursae Majoris III enacted the ADA in 182 in order to ensure that all its citizens could fully participate in all aspects of society. It believed it was unfair to refuse employment, housing, service, and other accommodation based solely on factors such as "race, planetary origin, colour, religion, sex, age, marital status, sexual orientation, or mental or physical disability."5

The ADA defines race as "a sentient biological species, such as Homo sapiens, or a distinct ethnic group within such a species."6 It defines a disability as "a mental or physical characteristic that substantially limits one or more major life activities of an individual."7 It also states that discrimination does not have to specifically name a protected group, but if "standards, criteria, or methods of administration...have the effect of discrimination on the basis of race, planetary origin, colour, religion, sex, age, marital status, sexual orientation, or mental or physical disability", that shall be deemed discrimination.

The ADA provides several reasons why an employer may not have to comply. If "reasonable accommodation" cannot be made for a disabled employee or customer, or if making such an accommodation would cause "undue hardship" or would "fundamentally alter the nature of the good, service, facility, privilege, advantage, or accommodation being altered", compliance is not necessary.8

IV

In the First District Court of 36 Ursae Majoris III, the plaintiff claimed that his natural inability to walk or run for a sustained period of time qualified as a disability under the ADA. Plaintiff also claimed that the CAFL’s rule which stated "Competitors may not fly during the match" was discriminatory against the Evi’ru and other winged races.9

Defendant did not contest that plaintiff’s inability to walk was covered under the ADA. The defendant instead claimed that allowing flight and permitting the football to be struck with the wings would constitute a "fundamental alteration" to their product, the game of football. In addition, it would provide an unfair advantage to K’ch’tll’k over those players who could only remain on the ground. Plaintiff pointed to K’ch’tll’k’s university team and believed it showed that despite the waiver, the game being played was undeniably football and was therefore not a "fundamental alteration"

The defendant also raised constitutional issues, citing Article V, Section 12 of the Constitution of the L’nhraei Commonwealth of Planets, which prohibits "discrimination based on race, planetary origin, colour, religion, sex, age, marital status, sexual orientation, or mental or physical disability" but also says nothing shall "interfer[e] with the freedom of association among any group, organisation, or business other than the government of the Commonwealth or any member world, or in such a way that favours certain groups over others."

The jury in the District Court rejected the defendant’s argument that waiving the requested rules would be a "fundamental alteration" to football and determined that the waiver of the rules should be granted. They found that the CAFL had violated the ADA’s prohibition of discrimination on the basis of race and that the prohibition of flying did indeed discriminate against the Evi’ru.

In the First Appellate Court of 36 Ursae Majoris III, the CAFL argued that the jury was incorrect in finding that the prohibition against the use of hands was not "fundamental" to football. The defendants claimed that not allowing players to use their hands was what distinguished the game from other forms of football, such as rugby or American football. They also believed that the District Court judge had improperly instructed the jury by telling them to consider the ADA and not the Commonwealth Constitution.

The Appellate Court judge ruled that since "The powers not delegated to the Commonwealth by this Constitution are reserved to the member worlds, or to the people"10, the judge called the ADA constitutional, saying the Commonwealth Constitution applied only to acts of Parliament, not individual member worlds. The judge upheld the conviction and let stand the waiver of the rules prohibiting flight and concerning handling the ball.11

In its appeal to the Supreme Court of 36 Ursae Majoris III, the CAFL repeated its arguments that it raised before the Appellate Court. It also pointed to the law making 36 Ursae Majoris III a member of the Commonwealth, in which the world is required to guarantee the rights granted under Article V of the Commonwealth Constitution.12 However, the Supreme Court upheld the ruling of the Appellate Court, saying that any violation of the Commonwealth Constitution would have to be dealt with in a Commonwealth court, not a court of a member world.13

V

This court must look at two issues. It must determine whether the lower courts were correct in finding whether a violation of the ADA occurred, and it must find whether the ADA itself violates the Commonwealth Constitution.

According to the ADA, racial discrimination occurs when a policy effectively keeps out a race, even if that policy does not specifically mention that race.14 Since the Evi’ru move primarily by flight and cannot move very well by walking or running, the rule prohibiting flight does serve to exclude them from playing the game of football.

Both sides agree that for K’ch’tll’k to play, it would be necessary to allow him to fly and to manipulate the ball with the hands. They also agree that his inability to walk or run is a disability as covered by the ADA.15 Their case therefore rests on the exceptions provided by the ADA to exempt an employer from compliance.

The CAFL did not contend that the changes would be an undue hardship. Other than possibly re-printing rulebooks and communicating the changes in the rules, which are done routinely every year, there would be no financial cost in allowing K’ch’tll’k to fly and to handle the ball.16

The main argument of the CAFL was that allowing the waiver would "fundamentally alter" the game. Perhaps it was inevitable that, given the act passed by the Scottish Parliament and King James II in 840 PUC outlawing "the futballe and the golf"17, that the paths of soccer and sovereignty, fiat and football, would once again cross. It now falls to this court to determine What Is Football.

The original rules of football, adopted in 441 PUC on Earth, where the game originated, stated "A player shall be entitled to run with the ball towards his adversaries’ goal if he makes a fair catch, or catches the ball on the first bound"18. The current rules specifically allow the use of hands to "the goalkeeper, inside his own penalty area", although the goalkeeper may not "tak[e] more than six seconds while controlling the ball with his hands.19

In some sense, football, like baseball, basketball, cricket, golf, and other sports, is not essential at all. The purpose of a game is simply amusement, and all the rules are arbitrary. For professional athletes, however, the rules of competition are equivalent to the policies and procedures of any other business. But are these rules truly essential to the game of football, as the ADA requires? If this court may order a football league to waive a rule, this decision would apply in the future to claims of discrimination in other sports.

Rule 5-1 of the rules of golf states "The ball the player uses shall conform to requirements specified in Appendix III," which in turn says "The weight of the ball shall not be greater than 1.620 ounces avoirdupois" and "The diameter of the ball shall not be less than 1.680 inches". Golf was certainly played by 840 PUC, as evidenced by the Scottish law outlawing it, but it was over 450 years later, in 385 PUC, when golf’s two governing bodies, the Royal and Ancient Golf Club of St Andrews (R&A) and the United States Golf Association (USGA) set a size limit of 1.62 inches. Eleven years later, in 374 PUC, the USGA changed the maximum size to 1.68 inches. It was another 35 years before the R&A adopted the larger ball. In the meantime, golfers who played in North America and Europe, including professionals, had to use balls of different sizes depending on the location of the tournament. The British Open, one of golf’s four major tournaments and held in Europe, was attended by many North American golfers, many of whom won despite the variation in the size of the ball.20 While the 1.68-inch limit is arbitrary, allowing a player to use a larger ball, even if they were unable to hit the ball as far, would certainly be unfair.

When the game of basketball was invented by James Naismith putting up two peach baskets in his university’s gymnasium, the baskets just happened to be hung 10 feet high. This 10-foot height is still used more than 500 years later. Yet, had the railings been 9 feet or 11 feet high, that might very well be the current height of the basket. In competitions held by the Commonwealth Basketball Association (CBA), as well as by some leagues on Earth, the sides of the free-throw lane form right angles with the lines indicating out-of-bounds.21 In international competitions, using the rules created by the Fédération Internationale de Basketball (FIBA), the free forms not a rectangle but a trapezoid.22 In international competition such as the Olympic Games, FIBA rules are used even for teams who normally play on a differently-marked court.

During the seventh inning of many baseball games, the fans sing a song entitled "Take Me Out to the Ball Game", the lyrics of which are:

Take me out to the ball game,
Take me out with the crowd.
Buy me some peanuts and cracker jack,
I don't care if I never get back,
Let me root, root, root for the home team,
If they don't win it's a shame.
For it's one, two, three strikes, you're out,
At the old ball game.23

This tradition goes back centuries, as do these lyrics, and this "seventh-inning stretch" could be considered an essential part of a baseball game. It occurred at the final World Series game in 266 PUC between the London Kings and the Gotham City Bats, was re-introduced at the games of the current Commonwealth Baseball League and is still sung at every one of those games. Many jurisdictions have passed "three-strike laws", in which a person who is convicted three times receives a life sentence.24 The reference is obviously to baseball, in which "A batter is out when…[a] third strike is legally caught by the catcher".25

"A base on balls is an award of first base granted to a batter who, during his time at bat, receives four pitches outside the strike zone."26 Four balls and "three strikes, you’re out" are among the baseball rules almost everyone knows, whether a fan or not. Many baseball scoreboards have individual lights to indicate the batter’s current count of balls and strikes, which is not something that can easily be changed without "undue hardship".

In 459 PUC, the original rules of baseball were first written down. One states "Players must take their strike [turn at bat] in regular turn."27 As with the football rules of The Football Association, one could consider these original rules as the "essential" sport. Yet in 334 PUC, one of the most controversial rules was adopted. It states that "A hitter may be designated to bat for the starting pitcher and all subsequent pitchers in any game without otherwise affecting the status of the pitcher(s) in the game."28 This "designated hitter" rule clearly changes the original rule requiring players to bat, and only one division of Major League Baseball, the American League adopted it. The National League chose to require the pitcher, like all other players, to take a turn at bat. The current Commonwealth Baseball League has a similar situation. One league uses a designated hitter; the other does not.

Despite the lyrics of "Take Me Out to the Ball Game" and the scoreboards and the adoption of baseball terms in other fields, it was not always "three strikes, you’re out". It was also not always four balls required for a player to receive a free base. In 426 PUC, the number of "called balls" required for a base on balls was not four, nine. This was gradually reduced over the next ten years. In 418 PUC, four strikes were allowed, although that only lasted one season.29 If a player could prove medically that a disability made it twice as hard for him to hit the ball, would fans then sing, "And it’s one, two, three-four-five-six strikes you’re out / At the old ball game"? Would criminals then be subject to a "six-strike" law?

Given all these changes, is it possible to reduce football or any sport to what is absolutely essential? "The Game of Golf consists of playing a ball from the teeing ground into the hole by a stroke or successive strokes" (italics in original)30. A basketball team is supposed "to throw or tap the ball into its own basket and to prevent the other team from scoring."31 In baseball, each team "win[s] by scoring more runs than the opponent."32 The rules of football provide that "The team scoring the greater number of goals during a match is the winner."33 Clearly, however, it must be more. If two football teams had to score a goal by bouncing an orange ball and making it go through a raised hoop, they would no longer be playing football. Some sort of specifications and procedures are necessary.

There have been many changes to the rules in all sports over the years. Rarely are these changes made simply to tinker with the rules. Many people feel the designated hitter makes baseball more exciting, while others believe all players should bat. A 10-foot high basketball hoop may be arbitrary, but it has been that way since the game’s invention. Were there no limit on the size and weight of golf balls, a player would easily be able to hit the ball 350 yards or more, making existing courses obsolete.

Similarly, the prohibition against the use of hands in football, while not in the original rules, serves to distinguish it from sports such as rugby or American football, in which players are allowed to carry the ball or throw it to another player. The ADA says:

For purposes of this article, consideration shall be given to the employer’s judgement as to what functions of a job are essential, and if an employer has prepared a written job description before advertising or interviewing applicants for a job, this description shall be considered evidence of the essential functions of the job.34

The goal while playing is to win according to the "written job description" of the rules, whatever the governing body calls "the rules" must be essential. To find otherwise would allow the rules of sport to be set by the legislature, a function certainly not appropriate for government. Should a version of football be invented in which flying is a requirement, that would be just as essential as not flying is to the CAFL’s sport.

VI

All these rule changes could lead to a conclusion that no rule is "essential" to a sport and any of them could be changed. Even if it were decided that as long as the game is still recognisable as the same sport, it is a "reasonable accommodation", there is still another question before this Court, the constitutionality of the ADA.

L’nhraei, and the Commonwealth, were founded on principles of the rights of the individual. Certainly that principle is in play here, and there is a conflict between the rights of K’ch’tll’k and the rights of the CAFL. But what exactly are those rights?

Article V, Section 1 of the Commonwealth Constitution states:

The Commonwealth, or any member, agency or agent thereof, shall, without exception, other than specifically provided in Article V, Section 15, adopt no law, rule, or regulation restricting in any way freedom of speech, thought, expression, ideas, opinions, association, religion, or of the press or media, nor shall any citizen be prohibited from attending any public assembly, nor denied a process to petition government for a redress of grievances.

Article V, Section 12 reads:

  1. Every individual is equal before and under the law and has the right to the equal protection and the equal benefit of the law without discrimination, and, in particular, without discrimination based on race, planetary origin, colour, religion, sex, age, marital status, sexual orientation, or mental or physical disability.
  2. This section shall not be construed in such a way that interferes with the freedom of association among any group, organisation, or business other than the government of the Commonwealth or any member world, or in such a way that favours certain groups over others.

Article V, Section 16 provides that "The powers not delegated to the Commonwealth by this Constitution are reserved to the member worlds, or to the people." Nowhere in the Constitution is Parliament or the Commonwealth empowered to outlaw any form of discrimination. Clearly, this power is reserved to the member worlds. Article V, Section 2 says, "No person shall be deprived of his or her property without his or her consent and without due and just compensation." A business and its profits are the property of its owners, and requiring that those profits be used on what the government deems essential would be a violation of that section. As such, whatever an owner deems the essential parts of his or her business must be essential. In addition, Article V applies to laws passed by member worlds as well as Acts of Parliament. In the law making 36 Ursae Majoris III a member of the Commonwealth, it states that "The rights and freedoms guaranteed under Article V of the Constitution of the L’nhraei Commonwealth of Planets shall apply to laws passed by the legislature of 36 Ursae Majoris III."35

All citizens of the Commonwealth must be treated equally under the law. Had K’ch’tll’k been convicted of a crime, and given a longer sentence solely because he is an Evi’ru, that would certainly be illegal under Article V, Section 12, paragraph 1. The rules of football, while called "laws", are not law in the legal sense. They carry no penalty greater than disqualification for one or more games.

While preventing discrimination wherever it occurs may be a goal many people feel is worthwhile, Article V, Section 12, paragraph 2 makes it very clear that it applies only to discrimination by the government of the Commonwealth or the government of any world which is a member of the Commonwealth.36 Whether the CAFL ought to allow K’ch’tll’k to play can be debated, whether or not it must is quite clear. As a "group, organisation, or business", the CAFL is entitled to freedom of association, which includes the freedom to not associate with a particular individual or group. Others may protest, or withdraw their patronage if they disagree with whom the CAFL refuses to associate with, but they do not have a right to force their way in.

This Court finds that the ADA, though well-intentioned, is unconstitutional and is hereby declared null and void. The judgement of the Supreme Court of 36 Ursae Majoris III is hereby reversed.

It is so ordered.

 

1    18 36 UMa III Code, §5000 et seq.

2    Law 12 of the Laws of Football

3    Law 12 of the Laws of Football

4    Q. "Does a penalty kick guarantee a goal?"
      A. "Not always. The goalkeeper is allowed to attempt to stop the ball."
      Q. "How often is a goal scored from a penalty kick?"
      A. "According to the statistics kept by the league, last season 72.3 percent of all attempted penalty kicks were converted into a goal."
      Q. "What about prior seasons?"
      A. "Let’s see – in 183, it was 69.8 percent, in 182 71.1 percent, in 181 74.9 percent."
      Q. "Are these kicks significant in determining the outcome of a match?"
      A. "Oh, yes. Many matches are won by a single goal. It’s not as common, but there have been matches in which the final score was 1-0 and that one goal was scored on a penalty kick." 185-1139 1D 36 UMa III 278

5    Hearings of the Assembly of 36 Ursae Majoris III, A. Rec. 192, 28 Germinal 181

6    18 36 UMa III Code, §5001(1)

7    18 36 UMa III Code, §5001(2)(e)

8    18 36 UMa III Code, §5003

9    185-1139 1D 36 UMa III

10   Commonwealth Constitution, Art. V, §16

11   185-452 1A 36 UMa III

12   4 LCPC 18

13   185-39 SC 36 UMa III

14   18 36 UMa III Code, §5002(b)

15   185-1139 1D 36 UMa III 12

16   185-1139 1D 36 UMa III 15

17   Anent wapinschawing
    Item it is ordanyt and decretyty th[a]t wapinschawing be haldin be the lordis and baronys spir[itu]ale a[n]d temp[or]ale four tymes in the ye[i]r And at the futballe and the golf be        vt[er]ly c[r]yit do[u]ne and not wsyt Ande at the bowe m[er]kis be maid at all p[ar]och kirkis a pair of buttis And schuting be wsyt Ilk su[n]day And th[a]t Ilk ma[n] schut six              schottis at the lest wnd[er] the payne to be Raisit apone thame th[a]t cu[m]is not at the lest ijd to be giffin to thame th[a]t cu[m]is to the bowe m[er]kis to the drink And for to be wsyt fra pasche till alhallomess ent[er]and be the nixt mydsom[er] w[i]t[h] all th[e]r geir w[i]t[h]out sonze And [th{e}r] that th[e]r be a bowar ande a fleg[er] in Ilk hede towne of the schyr[e] And at the towne furnysh of stuf and graithe eft[ir] the nedis th[er]to th[a]t he may s[er]ve the cu[n]trie w[i]t[h] And tuichand the futball and the golf we ordain it to be punyst be the baronys wnlawe And gif he takis it not to be tane be the kingis officiaris And gif þe p[ar]ochin be mekill th[a]t th[er] be iij or iiij payr[e] of buttis in Ilk placis as best accordis th[er]for And Ilk ma[n] w[i]t[h]in th[a]t p[ar]ochin passit xij yeris sall wse schuting (italics added)

18 The original rules adopted by The Football Association in Messidor 441 PUC were as follows (bold in original):

I.

The maximum length of the ground shall be 200 yards, the maximum breadth shall be 100 yards, the length and breadth shall be marked off with flags and the goal shall be defined by two upright posts, 8 yards apart, without any tap or bar across them.

II.

The Game shall be commenced by a place kick from the centre of the ground by the side winning the toss, the other side shall not approach within 10 yards of the ball until it is kicked off. After a goal is won the losing side shall be entitled to kick off.

III.

The two sides shall change goals after each goal is won.

IV.

A goal shall be won when the ball passes over the space between the goal posts (at whatever height), not being thrown, knocked on, or carried.

V.

When the ball is in touch the first player who touches it shall throw it from the point on the boundary line where it left the ground, in a direction at right angles with the boundary line.

VI.

A player shall be out of play immediately he is in front of the ball, must return behind the ball as soon as possible. If the ball is kicked past a player by his own side, he shall not touch or kick it or advance until one of the other side has first kicked it or one of his own side on a level with or in front of him has been able to kick it.

VII.

In case the ball goes behind the goal line, if a player on the side to whom the goal belongs first touches the ball, one of his side shall e entitled to a free kick from the goal line at the point opposite the place where the ball shall be touched. If a player of the opposite side first touches the ball, one of his side shall be entitled to a free from a point 15 yards outside the goal line, opposite the place where the ball is touched.

VIII.

If a player makes a fair catch he shall be entitled to a free kick, provided he claims it by making a mark with his heel at once; and in order to take such a kick he may go back as far as he pleases, and no player on the opposite side shall advance beyond his mark until he has kicked.

IX.

A player shall be entitled to run with the ball towards his adversaries’ goal if he makes a fair catch, or catches the ball on the first bound; but in the case of a fair catch, he makes his mark, he shall not then run.

X.

If any player shall run with the ball towards his adversaries’ goal, any player on the opposite side shall be at liberty to charge, hold, trip, or hack him, or to wrest the ball from him; but no player shall be held and hacked at the same time.

XI.

Neither tripping nor hacking shall be allowed, and no player shall use his hands to hold or push his adversary, except in the case provided for by Law .

XII.

Any player shall be allowed to charge another, provided they are both in active play. A player shall be allowed to charge if even he is out of play.

XIII.

A player shall be allowed to throw the ball or pass it to another if he make a fair catch, or catches the ball on the first bound.

XIV.

No player shall be allowed to wear projecting nails, iron plates, or gutta percha on the soles or heels of his boots.

19   Law 12 of the Laws of Football

20   "Historical Changes to the Rules of Golf", R. Hodgkins (182)

21   Rule 1 of the Rules of Basketball, CBA

22   Rule 2, Article 2-4-3, Official Basketball Rules (FIBA)

23    "Take Me Out to the Ball Game", J. Norworth, 379 PUC

24   See 21 UFPC, §12000 et seq., 17 c Cancri IV, §4100 et seq., 19 UNC, §2000 et seq.

25   Rule 6.05(b), CBL Rules of Baseball

26   Rule 2.00, CBL Rules of Baseball

27   16th Rule, Rules and Regulations of the Knickerbocker Base Ball Club, Adopted September 23, 1845 [5 Fructidor 459 PUC]

28   Rule 6.10(b), CBL Rules of Baseball

28   Historical Rule Change Time Line, "Baseball Almanac", various authors (185)

29   Rule 1-1 of the Rules of Golf, R&A and USGA

30   Rule 1-1-1 of the CBA Rules of Basketball

31   Rule 1.02 of the Rules of Baseball, CBL

32   Law 10 of the Laws of Football, FIFA

33   18 36 UMa 3 Code, §5005(a)(2)

34   4 LCPC 18

35   See Elaine Doyle v Law Firm of Beacon, Norris, and Verne (81-24 20 LMi III 3D), Joran tr’Kele v Fuller Industries, Inc. (121-87 1D 20 LMi III), and Rachel and Kimberly McCloud v Connors High School (180-247 5 LCPA)