## Facts

- Fred W. Rensing attended Indiana State University (ISU) on an NCAA grant-in-aid football scholarship offered through ISU’s head coach and approved by the Board of Trustees.
- The grant-in-aid was renewable annually (up to four years) and provided tuition, room and board, fees, books, tutoring, and limited game tickets.
- The agreement described the assistance as an educational grant tied to Rensing’s participation in varsity football.
- The grant provided that financial aid would continue even if Rensing suffered an injury during supervised play that made further participation medically inadvisable, though ISU could request other assistance from him to the extent of his ability.
- On April 24, 1976, during ISU spring football practice, Rensing sustained a catastrophic neck injury and became a quadriplegic.
- Rensing filed a claim with the Industrial Board of Indiana seeking workers’ compensation benefits for permanent total disability and related medical expenses.

## Issues

1. Whether a student-athlete receiving an NCAA grant-in-aid in exchange for participation in varsity football is an “employee” of the university under the Indiana Workmen’s Compensation Act.
2. Whether the scholarship benefits constituted “pay” sufficient to establish an employer-employee relationship for injuries sustained during supervised intercollegiate athletics.

## Decision

- The Indiana Supreme Court granted transfer, vacated the Court of Appeals’ decision, and reinstated the Industrial Board’s denial of benefits.
- The court held that Rensing was not an employee of the ISU Board of Trustees within the meaning of the Indiana Workmen’s Compensation Act.
- The court concluded the parties did not mutually intend to create an employer-employee relationship; the grant-in-aid was educational support rather than wages.
- NCAA rules limiting compensation and framing scholarships as educational aid supported treating the arrangement as non-employment.
- The continuation of benefits after disabling injury and Rensing’s primary status as a student further distinguished the relationship from traditional employment.

## Legal Principles

- Employee status under the Indiana Workmen’s Compensation Act depends on whether the parties intended to create an employment relationship, not merely on the existence of valuable benefits.
- An NCAA grant-in-aid structured as educational assistance, consistent with amateur-athletics rules barring pay-for-play, is not “pay” establishing an employer-employee relationship.
- A university student’s primary educational relationship, even when coupled with required athletic participation, is generally outside the scope of “employment” contemplated by the workers’ compensation statute.
- Scholarship terms that continue benefits despite inability to perform athletic participation weigh against characterizing the arrangement as wages exchanged for services.

## Conclusion

The Indiana Supreme Court held that a scholarship football player injured during university-supervised practice was not an employee for purposes of workers’ compensation because the grant-in-aid reflected educational financial assistance under amateur-athletics rules rather than wages under an intended employment relationship.


Rensing v. Ind. State Univ. Bd. of Trs., 444 N.E.2d 1170 (Ind. 1983)