The 2010 Quinnipiac ruling centered on Title IX, varsity participation and the structure of competitive cheer. Acrobatics & Tumbling and STUNT later addressed many of the problems identified by the court.
On July 21, 2010, a federal court ruled that Quinnipiac University could not count its women’s competitive cheerleading team as a varsity sport for Title IX compliance.
The decision quickly generated a much broader headline: Cheerleading is not a sport.
That description omitted the central issue in the case.
U.S. District Judge Stefan R. Underhill did not rule that cheerleaders were not athletes or that competitive cheer lacked athletic difficulty. He ruled that Quinnipiac’s program did not meet the federal standard for a legitimate varsity athletic participation opportunity.
The distinction shaped the next era of college cheer.
Quinnipiac cuts women’s volleyball
The case began in March 2009 when Quinnipiac announced that it would eliminate women’s volleyball, men’s golf and men’s outdoor track and field.
The university also announced plans to establish women’s competitive cheerleading as a varsity program.
Quinnipiac intended to count the competitive cheer team’s 30 roster positions among the athletic opportunities it provided to women. Those positions helped the university’s Title IX participation numbers.
Five volleyball players—Stephanie Biediger, Kayla Lawler, Erin Overdevest, Kristen Corinaldesi and Logan Riker—joined head coach Robin Sparks in filing a lawsuit against the university.
They argued that Quinnipiac would deny women equal varsity participation opportunities by eliminating volleyball. They also challenged the university’s decision to count competitive cheer as a varsity sport under Title IX.
The court agreed.
The Title IX calculation
Title IX prohibits sex-based discrimination in education programs receiving federal funding. In college athletics, schools must provide equal athletic opportunities for male and female students.
Schools have multiple ways to demonstrate compliance. One is to provide athletic participation opportunities that are substantially proportionate to undergraduate enrollment.
Women represented 61.87% of Quinnipiac’s undergraduate enrollment during the period examined by the court. The court determined that women received 58.25% of the university’s recognized varsity participation opportunities.
That produced a gap of 3.62 percentage points.
The court also examined Quinnipiac’s roster management. The university had increased roster targets for some women’s teams, restricted men’s rosters and counted certain women’s cross-country athletes again in indoor and outdoor track.
The competitive cheer roster became a major part of the case.
If the court counted those 30 athletes, Quinnipiac moved closer to proportionality. If it excluded them, the university remained short of the participation opportunities needed to support its Title IX position.
Why competitive cheer did not qualify
The case was not decided by measuring the difficulty of tumbling passes, baskets or partner stunts.
The court evaluated how Quinnipiac’s program operated.
Competitive cheer was not recognized by the NCAA as a championship or emerging sport. The activity also lacked consistent rules, standardized scoring, a defined season and an established postseason system.
Quinnipiac competed in events that used different formats. Opponents did not always follow the same rules or scoring systems. Some events did not function like direct varsity competition between colleges.
Underhill concluded that competitive cheer was “too underdeveloped and disorganized” to provide genuine varsity athletic participation opportunities at that time.
The ruling applied to Quinnipiac’s program and the Title IX evidence presented in 2010. It was not a universal finding that every form of cheerleading lacked the qualities of a sport.
The court required Quinnipiac to continue sponsoring women’s volleyball during the 2010-11 season and submit a plan for Title IX compliance. The case record details the ruling and subsequent litigation.
Acrobatics & Tumbling competed first
College administrators and coaches were already working to establish a varsity sport using skills from cheerleading and gymnastics before the court issued its July decision.
Azusa Pacific, Fairmont State and Quinnipiac were interested in converting existing competitive cheer programs. Baylor and Oregon planned to add a new women’s varsity sport.
The first collegiate Acrobatics & Tumbling meet took place in 2010.
The original group included Azusa Pacific University, Baylor University, Fairmont State University, the University of Maryland, the University of Oregon and Quinnipiac University.
