## Facts

- Fred W. Rensing played varsity football at Indiana State University (ISU) on a renewable NCAA grant-in-aid scholarship.
- The scholarship provided tuition, room, board, fees, books, tutoring, and a limited number of game tickets.
- The written agreement conditioned the aid on “active participation in football competition” and contemplated continued aid if injury made participation medically inadvisable, with possible alternative assistance duties within his ability.
- On April 24, 1976, during supervised spring football practice, Rensing suffered a severe neck injury that left him quadriplegic.
- Rensing filed a claim with the Industrial Board of Indiana seeking workers’ compensation benefits for permanent total disability and medical expenses.
- A single hearing member denied the claim, concluding no employer–employee relationship existed between Rensing and ISU’s Board of Trustees under the Indiana Workmen’s Compensation Act.

## Issues

1. Whether a varsity football player receiving an NCAA grant-in-aid scholarship and injured during supervised university practice is an “employee” of the university’s trustees under Indiana’s Workmen’s Compensation Act.

## Decision

- The Court of Appeals reversed the Industrial Board’s denial and remanded.
- The court held that Rensing was an employee covered by the Indiana Workmen’s Compensation Act.
- It found a bargained-for exchange of athletic services for substantial scholarship benefits, consistent with “service for pay” in substance.
- It concluded the football services were not casual and were sufficiently connected to the university’s institutional business of educating students.
- It relied on the structured, supervised nature of team participation as support for university control over the means and manner of performance.

## Legal Principles

- An employment relationship for workers’ compensation may be found where parties exchange services for substantial economic benefits, even if benefits are furnished in kind rather than as wages.
- University oversight and direction of athletic participation may satisfy the control element commonly associated with employment status.
- Work is more likely within the Act when it is organized, ongoing, and tied to the institution’s regular operations rather than incidental or casual.
- Labels assigned by third-party athletic governance rules are not determinative; the analysis turns on statutory criteria and the substance of the exchange.

## Conclusion

The court held that a scholarship football player injured during supervised practice could qualify as a university employee for workers’ compensation purposes because the parties exchanged athletic services for significant scholarship benefits in an arrangement marked by institutional control and non-casual integration into the university’s operations.


Rensing v. Ind. State Univ. Bd. of Trs., 437 N.E.2d 78 (Ind. Ct. App. 1982)