This April, the NCAA granted a 6th year to Northern Illinois offensive lineman Ben Lueck. Luecks case is pertinent for two reasons; he was a non-medical redshirt during his freshman year in 2000 and he missed one season due to a non-football related injury the following year.
Lueck missed the 2001 season and the following offseason after suffering a serious head injury in a pedestrian-vehicle accident. He played in 2002 and won varsity letters in 2003 and 2004 before granted a 6th year this spring.
According to a release on the Northern Illinois website announcing the NCAAs decision, "The NCAA staff okayed the extension waiver, stating that Luecks injuries were extraordinary and not forseeable plus rose to the level of extraordinary circumstances."
Understanding NCAA Bylaw 30.6
According to the NCAA Manual Bylaw 14.2.1, all student-athletes have five calendar years to complete four years of eligibility. Bylaw 126.96.36.199 allows for waivers to the five-year rule, "The Committee on Student-Athlete Reinstatement, by a two-thirds majority of its members present and voting, may approve such additional waivers to the five-year rule as it deems appropriate."
The key to understanding the NCAAs decision-making process is Bylaw 30.6.1 - Waiver Criteria. The two key phrases are beyond the control of the student-athlete and institution and extraordinary or extreme hardship.
In By-laws 188.8.131.52 and 184.108.40.206, the NCAA lists a series of examples of what consitutes circumstances beyond control and circumstances within control. It is critical to note that both sets of examples are prefaced by the comments "include, but are not limited to, the following."
The circumstance that was most pertinent to Luecks case, and will be in Teppers is 220.127.116.11.a:
Situations clearly supported by contemporaneous medical documentation, which states that a student-athlete is unable to participate in intercollegiate competition as a result of incapacitating physical or mental circumstances.
Note that the bylaw does not say the those circumstances must come from injuries suffered while training or competing for a particular sport. One common misconception about the five-year/10-semester rule waiver is that a player must miss two years, or the better part of two years, due to sport- or competition-related injuries. If this were the case, than Lueck would not have been granted a sixth year.
Other circumstances beyond a student-athletes control are:
- life-threatening or incapacitating injury or illness suffered by a member of the student-athletes immediate family,
- reliance upon faulty academic advice provided by the academic institution directly affecting a student-athletes eligibility status,
- natural disasters, and
- extreme financial difficulties which would prohibit the student-athlete from participating in intercollegiate athletics.
Circumstances which are within an athletes control and would not constitute sufficient reason for the NCAA to grant a waiver would include:
- a student-athlete choosing to attend a school that does not sponsor his/her sport,
- an inability to participate due to a failure to fulfill academic requirements,
- an inability to participate due to disciplinary reasons culminating in or resulting from a conviction,
- reliance upon misinformation from a coaching staff member,
- a redshirt year,
- sitting out because of a transfer year, or
- ignorance about the starting date of a student-athletes five-year period of eligibility.
In Luecks case, his redshirt year did not count against him, even though it was a circumstance within his control. The NCAA looked at what impediments he faced to completing his four years of eligibility (or in NCAA parlance, participation opportunity), his injuries constituted a circumstance outside of his control, and the waiver was granted.
Lupoi was redshirted in 2000, and missed the 2004 season with a foot injury. His circumstances fulfilled the 18.104.22.168.a criteria of being "unable to participate...as a result of incapacitating physical or mental circumstances."
Lymans case was slightly different. He missed the 2002 season after undergoing surgery for a torn hamstring. Although he missed significant parts of several other seasons, including the final eight games of 2004, the NCAA has shown no history of allowing student-athletes to aggregate time missed because of injury. In several of the cases where the NCAA granted a 6th year, a player was injured in the 1st or 2nd game of the season. There were no cases where a player was allowed to play deep into the season and allowed to have that season count as a redshirt or medical hardship year. One could argue that Lymans injuries fit the 22.214.171.124.a criteria, but his injuries didnt prevent him from playing 20% of his teams games (14.2.4.c) in any of the other seasons in question.
Other Cases Where a 6th Year Was Granted
The NCAA bylaws dont specifically state that a student-athlete has to earn a degree after five years, but doing so is likely to help his or her case. Below is a partial list of cases where student-athlete either were or werent granted a 6th year of eligibility. If the research showed the student-athlete earned a degree, its pointed out, if theres no mention of a degree it does not mean that the student-athlete in question failed to graduate in five years.
Jon Beutjer - Illinois
Missed most of one season while at Iowa after an altercation where he suffered a concussion from a teammate; also redshirted after transferring to Illinois.
Spencer Brinton - Michigan
Had a medical redshirt year in 1998, played 2 games in 2003 before having season-ending surgery; also went on two-year LDS mission.
Amp Campbell - Michigan State
Sat out one year because of academic trouble, missed one year with a neck injury. Earned degree.
Lloyd Clemens, Michigan State
Missed two years - one year because of redshirting, another year because of transferring. Earned degree. (This would appear to be a case where both events would be classified as circumstances under a players control.)
Paul Harker - Michigan State
Received medical redshirt in 1999 due to concussion; missed entire 2000 season with a broken left foot
Harrison Hill - Kansas
Received medical redshirt in 1999 due to broken ankle; missed final nine games in 2002 due to broken shoulder blade.
Katie Hnida - New Mexico State
Missed 1999 and 2001 due to medical problems.
Josh Huston - Ohio State
Missed freshman year with knee injury; missed sophomore year with surgery on his right knee and hips.
Kyle Johnson - Syracuse
Suffered season-ending injury during the 2000 season opening game; redshirted in 1996.
Korey Kirkpatrick - Miami (Ohio)
Redshirted in 1999 due to a knee injury suffered in high school, missed senior year after sufering a torn ACL in the 2nd game of the season. Earned degree.
Brandon Phillips - Arizona
Injured knee and head during redshirt freshman year; missed most of a 5th year because of a knee injury; would have to miss 3 games during his 6th year because of an agreement with an agent.
(This is an odd case where a student-athlete was granted a 6th year, but was given a pass of meeting any high moral ground, as the three-game suspension for signing with an agent would incidate.)
Pat Reddick - Washington
Missed 1998 and 1999 seasons because of knee injuries.
Jason White - Oklahoma
Suffered season-ending knee injury in the 2nd game of the 2002 season; injured back and ankle in 1999 and received a medical hardship to preserve a year of eligibility.
Marcus Woodson - Mississippi
Missed all of 2003 and most of 2002 after suffering a knee injury in the 2nd game of the season. Earned degree.
Corey Yates - Southern Mississippi
Missed 2002 and all but one game in 2001 with two different knee injuries.
Cases Where a 6th Year Was Denied
Gerald Harris - Washington
Redshirted with thumb injury suffered during spring practice in 1995 - note, not a medical redshirt; sidelined with knee injury in 1997. (Harris might have needed to apply for a medical hardship for one of the seasons where he was injured.)
Mike Rathe - South Carolina
Lost one year when the JV schedule at San Diego resulted in only one game; played two games at a community college before suffering a season-ending injury. Earned degree.
Where to from here?
In the case of Mike Tepper, its still far too early to take any action. Any application for a 6th year wouldnt take place until after the completion of his 5th year, which means that Tepper and the Bears still have to go through four full seasons before a decision has to be made. In the meantime, its anybodys guess what will happen with the NCAA and its bylaws. Just Section 30.6, which is just over one page out of a 510-page manual, has undergone 14 revisions in the past 14 years.
It will be worth watching the decisions of the Committee of Student-Athlete Reinstatement or a subcommittee to see if their attitudes towards granting waivers changes over time. But if its decision with regards to Ben Lueck this spring is any indication of their future decisions, Mike Tepper may be in luck after all.
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