No Pain, No Gain: the Consequences of the Coercive Culture of College Football

Amelia Lee

Edited by Sam Tonini, Danush Gade, Mac Kang, and Sahith Mocharla

On February 29, 2010, University of Mississippi (Ole Miss) football player Benner “Buster” Abram III collapsed during strength and agility drills. However––in stereotypical football culture––Ole Miss’ head strength and conditioning coach, Don Decker, allegedly told Abram that “if he didn’t join his teammates, he would be off the team,” inevitably challenging Abram and coercing him into continuing the workouts [1]. While Abram attempted to endure, he collapsed a second time; eventually transported to the hospital and later passed away. Yet despite Abram’s (likely/otherwise preventable) death, Decker stayed on as Ole Miss’ head strength and conditioning coach, where he was named the Collegiate Strength and Conditioning Coach of the Year in 2010 and later hired as the director of sports performance at New Mexico State. 

This tragedy is not an abnormality in the world of collegiate football. As of 2021, 22 Division I football players have died since 2000 due to exertion-related illnesses brought on during their team’s practice [2]. Despite these deaths, football programs and coaches face few consequences for violating the National Collegiate Athletic Association’s (NCAA) recommended safety precautions, allowing this culture of coercion to permeate within collegiate football. The core rationale of the lack of consequences culminates in a cultural issue that prioritizes toughness over safety.

Coaches can weaponize a player’s status through the form of status coercion; forcing their players into overexerting themselves whilst simultaneously causing players to avoid advocating against this culture because of the risks to their professional and collegiate dreams. Collegiate football’s culture––where coaches intentionally overlook injuries or pressure players to overexert themselves–– can even manifest through threats to playing time or potential removal of the player from the roster [3]. Stopping during intense workouts risks playing time, hurting their chances at transferring or ultimately the NFL draft. Therefore, through their positions of power, coaches “can control players because if they withhold opportunity as punishment, then players receive essentially nothing in return for their efforts” [4]. This specific form of coercion is status coercion, where “the power of coaches [determines] access to the limited resources available–scholarships and playing time” [5]. This ‘status coercion’ facilitates coaches to easily breach their duty of care without immediate pushback by the players. The coaches threatened Abram’s roster spot if he did not continue the workouts, despite reporting illness, illustrating how widespread this culture of coercion is across football programs. Understandably, because of their coach's status coercion, players fear speaking out “because it risks everything they’ve worked for…from [their] position, to money, to the coaches telling scouts that [they are] a trouble-maker” [6]. Therefore, this culture prevails, despite its harmful effects, partially because of the risks involved in advocating against it. 

Legal recourse, despite being an option, often falls on the side of the perpetrators.  Repeated settlements indicate how universities, rather than addressing these problems, can simply pay to silence victims––the ‘cheaper’ option. In late 2016, Doug Brenner, a former Oregon Ducks offensive lineman, and two other players were hospitalized for rhabdomyolysis, a life-threatening condition caused by muscle-tissue breakdown. Their coaches had forced them to “perform hundreds of pushups and up-downs without rest and denied water during the first full day of conditioning” [7]. In 2022, over civil allegations of the coaches’ negligence and dangerous workout techniques, Brenner settled with the University of Oregon. According to the United States Court, “settlements often involve the payment of compensation by one party in at least partial satisfactions of the other party’s claims, but usually do not include the admission of fault” [8] The settlement provided Brenner with $500,000, in return for Brenner dismissing the claims against his coaches. This response by the university implies to coaches that the university will unreservedly support their efforts, regardless of the harm to players’ safety, and offers  minimal recourse for players. By not admitting fault, the university mitigates the harmful press and impact of the case on its reputation. If they lost in court, their admission of guilt may dissuade future recruits from signing with the program, potentially costing the program in revenue if their recruits’ talents significantly decrease. 

These players––and their families––haven’t gone down without a fight. In response to these dangerous conditions, often perpetrated or facilitated by the administrations as well as coaching staff, many of the families of these athletes have sued the program(s) for negligence. To have grounds to sue for negligence, a plaintiff must prove the four elements of negligence: duty of care, breach of duty, causation, and damages. The NCAA Constitution states that “intercollegiate athletics programs shall…protect, support and enhance the physical and mental health and safety of student-athletes” [9]. Plainly, intercollegiate athletics programs have a duty of care in regards to their student-athletes. For coaches specifically, “courts generally apply a higher standard of care to coaches…because they can use their authority to put subordinates in potentially harmful activities” [10]. Applying this standard as a college football team’s duty of care, many of these families have sued the football programs for negligence, claiming that collegiate football teams coerce athletes to continue playing, despite symptoms of injury or poor health, making the staff liable for a player’s injury. 

College athletics, however, don’t operate in a vacuum. These are massive revenue generation enterprises, creating a conflict between duty of care administered to the player versus the pursuit of financial success [11]. Coaches force athletes to play through injury to produce wins, as “wins and championships translate into revenue…for university athletic departments and schools” [12]. Moreover, while athletic departments keep coaches on staff when the team has a successful season, poor seasons result in potential firings. This correlation between job security and successful records causes the coaches to prioritize winning, forcing their best players to continue to play so that they create optimal results. Cases like that of Greg Brooks Jr., a former LSU safety, highlight how coaching and training staff dismiss persistent injuries or illnesses to keep athletes playing. Brooks Jr. claims that “he ‘passed out’ during practice, and ‘then began to vomit’ minutes later in front of his coaches and athletic trainers” [13]. However, the LSU athletic trainer claimed he had vertigo and cleared him, despite these symptoms presenting themselves daily for 39 days until the team ultimately “made an appointment with a neurologist who discovered [his] brain tumor” [14]. 

The implementation of NIL (name, image, likeness) compensation for student athletes exacerbates the issue of the mistreatment of student athletes – perceiving them as employees rather than students – when these students lack worker protection claims under OSHA. The integration of NIL money into college football pays student athletes for their image, which their performance influences. In Johnson v. NCAA, the U.S. Court of Appeals for the Third Circuit ruled in favor of six former and current collegiate athletes who argued “that they should have been classified as employees of the colleges and universities and the NCAA under the FLSA” [15]. The Third Circuit created a test to determine if a student athlete is classified as an employee too: they perform services for another party primarily for their benefit, the receiving party is in control, and the student athlete receives compensation or in-kind benefits [16]. If athletes meet these requirements, OSHA may regulate their working conditions. However, OSHA’s jurisdiction covers private sector employees, but “a state university…is not covered by the Occupational Safety and Health Act of 1970 (OSH Act) and therefore OSHA standards do not apply to employees of [a public] university” [17]. This difference in jurisdiction limits the collegiate football programs under OSHA regulation. 22 states developed an OSHA-Approved State Plan, where individual states regulate safety and health programs, with OSHA approving and monitoring these plans; however, for the remaining 28 states, public employees lack clear workplace safety regulation [18]. If the Third Circuit test determines that a group of student athletes are also employees, but they play for a public university in one of those 28 states, then they still lack worker protection claims under OSHA. The classification of student athletes as employees extends the issue beyond neglect to workers’ rights as well. 

The involvement of the athletic trainer points to the pervasiveness of the practice; this is not just a coach problem––it is a systemic one. Similar to coaches, university athletic departments hire athletic trainers to return athletes to play when they experience injury or illness. The quicker that athletes return to the field, the better the team’s game results, and the more money the athletic department receives. Coaches (and the athletic department) are incentivized to pressure athletic trainers to clear athletes expeditiously so that they can continue playing, enabling situations where they may clear an athlete prematurely.

A negligence case requires establishing a causal link between the coach’s coercion and the athlete’s injury, which includes both the creation of injuries or the exacerbation of a preexisting one. Many athletes experience injury while playing their sport, even during practices or warm-ups where their bodies feel exerted. Solely having an injury does not create grounds for negligence. Athletes must demonstrate how the “breaching the duty of reasonable care constitutes a substantial factor in bringing about the plaintiffs injury” [19]. In the cases of Brenner and Abram, their coaches’ forcing them to do drills, despite their symptoms suggesting that their bodies felt overexerted, demonstrates their further injuries were causally linked to their coaches’ actions. In the case of Greg Brooks Jr., while the coaches and trainers may not have directly contributed to his condition, their failure to properly address it––accompanied by forcing Brooks Jr. to continue playing––increased the risk of injury and damage. These cases indicate how negligence does not merely create injuries, but also worsens existing ones.

In order to qualify as negligence, damages cannot merely be nominal; they must “profoundly impact the plaintiff’s interest” [20]. In Abram’s case, his coach’s coercion led to his death, leaving a toll on him, his family, and his loved ones. In the case of Brooks Jr., not treating his brain tumor when symptoms first arose allowed it to grow considerably, exacerbating its treatment and removal. Today, Brooks Jr. suffers from paralysis and a speech impediment after his surgery, disabilities that deteriorate his quality of life, including by inhibiting him from playing football. 

The intense pressure and coercion tactics of collegiate coaches, trainers, and other athletic staff can result in significant and permanent injury to their players. Combatting this norm of coercion and pushing athletes past their abilities can help create new safety standards to better protect athletes. Instituting new standards could include having more effective NCAA enforcement, punishing coaches, trainers, and other staff for their negligence rather than rewarding them, such as in Decker’s case. As is, the NCAA Constitution states that “the institution is responsible for protecting athletes,” with member institutions “left to determine [their] own response” to catastrophic events [21]. Moreover, it states these standards “without adopting an enforceable rule that defines specific ‘dos’ and ‘don’ts’ in these areas” [22]. It is not merely enough to state a constitutional principle – the NCAA should define their standards to more clearly stipulate the subsequent penalties imposed on coaches and institutions if they violate these terms. Considering coaches use coercive tactics and neglect players’ health because of revenue, they will likely follow these standards if they receive harsh fines, penalties, or even firings if they do not. It is imperative that the NCAA addresses this culture to protect student athletes’ health – cultivating an environment that ensures athletes’ safety while maintaining these programs as a source of enjoyment for all actors involved.

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[1] Dan Novak, Pushed too far: Overexertion has claimed lives of 22 Division I football players since 2000, CNSMARYLAND.ORG (Spring, 2021), https://cnsmaryland.org/interactives/spring-2021/pushed-too-far/.

[2] see [1]. 

[3] Nathan Kalman-Lamb, The End of College Football: On the Human Cost of an All-American Game, University of North Carolina Press (2024), https://www.jstor.org/stable/10.5149/9781469683492_kalman-lamb.

[4] see [3].

[5] see [3].

[6] see [3].

[7] Haley Larkin, Former Ducks Player Doug Brenner Settles with the University of Oregon, Loses Lawsuit Against NCAA, LAW COMMENTARY (May 14, 2022), https://www.lawcommentary.com/articles/former-ducks-player-doug-brenner-settles-with-the-university-of-oregon-loses-lawsuit-against-ncaa.

[8] Settlement, UNITED STATES COURTS, https://www.uscourts.gov/glossary?name=settlement (last visited Nov. 21, 2025).

[9] NCAA, NCAA Constitution, NCAA.ORG (Dec. 14, 2021), https://ncaaorg.s3.amazonaws.com/governance/ncaa/constitution/NCAAGov_Constitution121421.pdf.

[10] Roya R. Hekmat, Malpractice during Practice: Should NCAA Coaches Be Liable for Negligence, Loy. L.A. Ent. L. Rev. 613 (2002), https://digitalcommons.lmu.edu/cgi/viewcontent.cgi?article=1446&context=elr.

[11] Billy Hawkins, Just Do It: Sport, the Culture of Punishment, and Status Coercion, LPE Project (Jul. 21, 2022),  https://lpeproject.org/blog/just-do-it-sport-the-culture-of-punishment-and-status-coercion/.

[12] see [11].

[13] Robyn Weil & Erin Brady, Greg Brooks Jr. Speaks Out About Lawsuit Against LSU, Recovery from Brain Surgery, ABC NEWS (Feb. 3, 2025, 12:14 PM), https://abcnews.go.com/GMA/News/greg-brooks-jr-speaks-lawsuit-lsu-recovery-brain/story?id=118372917.

[14] see [13].

[15] Jimmy Balser, Johnson v. National College Athletic Association: Third Circuit Allows College Athletes’ Claim for Wages to Move Forward, CONG. RSCH. SERV. (Sep. 6, 2024), https://www.congress.gov/crs-product/LSB11223.

[16] see [15].

[17] Richard E. Fairfax, OSHA standards do not apply to state university employees., OCCUPATIONAL SAFETY & HEALTH ADMIN. (Oct. 11, 2006), https://www.osha.gov/laws-regs/standardinterpretations/2006-10-11.

[18] State Plan Frequently Asked Questions, OCCUPATIONAL SAFETY & HEALTH ADMIN., https://www.osha.gov/stateplans/faqs (last visited Nov. 21 2025).

[19] see [10].

[20] see [10].

[21] Donna Lopinao et al., The Drake Group Position Statement: College Athlete Health and Protection from Physical and Psychological Harm, THE DRAKE GROUP (Oct. 1 2019), https://www.thedrakegroupeducationfund.org/wp-content/uploads/2019/10/FINAL-Athlete-Health-and-Protection-Position-Paper.pdf.

[22] see [21].