B|H (Christi 8 Hemp Randy Angele —_ innate MarleD. Boyer : A | A Rhonda $ Smiths Bare] Hebert Steven Diebota K Atle a BOYER HEBERT, ABELS & ANGELLE Dominic Amato" Pawnee Atoemays and Councelareat Lave (4 Limited Lab Company) "Aso Licensed in Georin& Texas Special Counsel (Reply to Denham Springs Office) October 9, 2017 (VIA EMAIL gblackwell@atheist.org) Geoiiey T. Blackwell Staff Attorney American Atheist Legal Center RE: BHAA Client: Louisiana High School Athletic Association BHAA No. 193.001 Dear Mr. Blackwell: This law firm has the honor and privilege of representing the Louisiana High School Athletic Association. I am in receipt of your October 5, 2017 communication to Mr. Bonine, the LHSAA Executive Director, and look forward to discussing the contents of same with you in the very near future, However, prior to discussing this matter with you, I thought I would provide you with a written communication briefly setting out the status of the Louisiana High School Athletic Association and our position relative to the comments of your letter. Firstly, Louisiana High School Athletic Association is a private organization and it is not in any way, shape, or form a governmental entity, a quasi-governmental entity, and/or a state actor as contemplated by law and jurisprudence, This is clearly set out in the Louisiana Supreme Court decision of the case entitled Louisiana High School Athletic Association, Inc. versus State of Louisiana, 2012-1471 (La, 1/29/13 107 So. 3* 583). As such, the LHSAA is not bound and/or obligated to act in conformity with those obligations that have been cast upon our governments, public bodies, and the like. The LHSAA, as a private organization, clearly understands that it exercises no authority over the school districts of our great state. All decisions regarding the legal rights of a school district's principals, teachers, faculty, and students rest solely with those school districts. The LHSAA understands that these school districts have both a tremendous and terribly difficult obligation to protect the rights of its students and employees while also protecting the educational environment, safety, and integrity of the entire system. As such, the LHSAA would never suggest, much less ‘demand that a school district actin a certain manner when those obligations are involved. 401 East Mis Avenue | Breaux Bridge, LA 70517 Phone: (337) 332-0616 Fax: (397) 332-0633 1280 Del Exe Avenue | Denkam Springs, LA 70726 Phone: (225) 4648335. Fox: (225) 4644490 BHAALAWCOMPage 2 of 2 I note that your letter request that the LHSAA “send (you) a copy of the school district's policy regarding prayers at school events, including athletic contest.” It appears that you are asking the LHSAA to provide you with a poticy that belongs to Bossicr Parish School Board. The same paragraph continues and states that “we demand that such unconstitutional practices are put to an immediate end, and all schools in the district be reminded of their responsibilities under the law.” 1 simply do not understand why this demand is aimed at the LHSAA, as the LHSAA clearly does not legislate, draft, propose, invoke, and/or enact any policy for any school district in the State of Louisiana, However, I am aware that all school district policies are a matter of public record, @ review of that school district's website would certainly provide a link to its entire policy manual. Moreover, your correspondence also makes the following requests: 1. That any policies inftinging on a student’s free-speech rights to peacefully protest be reseinded immediately, and all schools in the district be instructed on student’s rights to expression; 2. That any practice of beginning student athletic contests with religious ceremonies be terminated, and all schools in the district be instructed as to the legal standards regarding such activities; and ‘That the relevant government bodies implement policies which protect these students? constitutional rights, and do not leave such decisions to individual schools. Once again, this request/demand seems to be erroneously aimed at the LHSAA. Lastly, your comespondence suggests that the “LHSAA and LSBA issued guidance permitting school officials to violate the rights of students and parents by curtailing students’ ability to engage in peaceful, non-disruptive expression...., the LHSAA and LSBA are complicit in those violations.” ‘Once again, a simple public records request to any of the school districts in the State of Louisiana ‘would have resulted with you being provided with a copy of a memorandum sent out to the member schools of the LHSAA. That piece of information would have clearly informed you that the LHSAA did nothing to violate the rights of any student, parent, teacher, principal, and/or any other person involved herein. As noted many times above, the LHISAA exercises no authority over school districts as it relates to individual school district's policies and procedures; and, thus the LHSAA does not have the capacity to issue guidance as suggested in your leer, Took forward to discussing this with you in further detail. I can be reached in our Denham Springs office at (225) 664-4335. With best regards, Sincerely, BOYER, HEBERT, ABELS & ANGELLE, LLC Mark D. Boyer MDBieec ce: Eddie Bonine, Executive Ditector- LHSAA Scott Smith, Superintendent-Bossier Parish Schools 401 Fas Mills Avenve | Breaux Bridge, LA 70517. Phone: (337) 332-0616 Fax: (337) 332-0633 1230 Del Este Avenue | Denhurn Springs, LA 70726 Phone: (225) 6644835 Fux: (225) 4644490 BHAALAW.COM