***
Read the full decision here. Underhill deferred to a letter from the U.S. Office for Civil Rights, which lays out specific guidelines for what constitutes a sport, and argues each potential sport should be looked at on a case-by-case basis to make sure it's structured and organized similar to existing varsity sports.

In Quinnipiac's case, Underhill wrote in his decision that while cheerleading may one day qualify as a sport, "Today, however, the activity is still too underdeveloped and disorganized to be treated as offering genuine varsity athletic participation opportunities for students."

In particular, Underhill took notice of two aspects of the cheerleading team that separated it from other varsity teams on the Quinnipiac campus. The first was the level of competition Quinnipiac faced, which included club teams, high school teams, All-Star teams not associated with a school, and squads that cheer for the purpose of entertainment and not competition.

"No other Quinnipiac varsity team is forced to play such a motley assortment of competitors," he wrote in the decision. "And it cannot be doubted that the quality of competitions is more variant across the competitive cheer season than across the seasons of the university's other varsity teams."

Additionally, Underhill noted that Quinnipiac competed under a variety of different scoring systems during the season, including those of groups not associated with the newly formed governing body, the National Competitive Stunt and Tumbling Association.

The AAUW (formerly known as the American Association of University Women) issued a press release in response to the ruling that supported the decision, saying in part: "While cheerleading can require great strength and skill, the primary purpose of a team must be competition in order to be considered a sport. AAUW has long supported this Department of Education definition."

Beyond this case, Underhill's decision could have a significant impact on future efforts to make cheerleading a varsity sport. Libby Sandler noted in the Chronicle of Higher Education that the decision:

"Provides a road map of sorts for elevating cheerleading to the status of what the judge called a 'legitimate varsity sport'--should it wish to go there. This includes, among other things, creating a championship based on teams' success during the regular season. It also means growing and standardizing the pool of competitors."

Underhill criticized Quinnipiac for failing to meet Title IX standards, saying the university fell 3.62 percent short of substantial proportionality and engaged in "roster manipulation" by inflating the number of women on the rosters of certain sports while decreasing the number of men on others. Quinnipiac also required its female cross country athletes to compete in indoor and outdoor track, which caused the rosters to swell.

In reaction to Underhill's ruling, the Women's Sport Foundation wrote that, "Quinnipiac's practices that limit the growth of women's sports are not isolated ... Thirty years after the passage of the law, schools should stop these dubious practices to fulfill the promise of Title IX."

Patrick Bohn is an Assistant Editor at Athletic Management.