In August 2025, the NCAA released its long-awaited Report on infractions committed by and for the University of Michigan football program. For compliance professionals, this case should be viewed not merely as a college sports story but as a case study in organizational misconduct, leadership failure, and cultural breakdown. Just as an FCPA enforcement action lays bare how companies slip into non-compliance, this NCAA decision reveals how one of the country’s premier football programs allowed systemic misconduct to flourish.

This week, in a five-part series, I will explore the case in detail. Today, in Part 1, we will review the background facts: what happened, who was involved, and how the NCAA investigation unfolded. In Part 2, we will move beyond the facts to examine the lack of a culture of compliance inside Michigan football. In Part 3, we’ll discuss the violations, penalties, and key lessons for compliance professionals. In Part 4, we will explore the consequences when regulators, such as the NCAA, become ineffective. In Part 5, we will explore lessons learned for the corporate compliance professional.

The Scheme’s Architect: Connor Stalions

Every corruption case has its “architect,” and here that title belongs to Connor Stalions. A former U.S. Naval Academy graduate and Marine, Stalions became obsessed with signal decoding, the football equivalent of corporate espionage. What began as a volunteer role with Michigan evolved into a full-time staff position, with his primary job being not recruiting, as his title suggested, but intelligence gathering.

Between 2021 and 2023, Stalions organized an extensive off-campus, in-person scouting operation. Using a network of acquaintances, interns, and even players’ friends, he orchestrated the purchase of tickets to opponents’ games, positioned people in prime seats to film sidelines, and then used that footage to decipher signals.

The scale was stunning. Across three seasons, there were 56 instances of scouting across 52 contests involving 13 opponents. Stalions even disguised himself on the sideline of a Central Michigan game in full coaching gear. He spent upwards of $35,000 on tickets in a single year, often buying burner phones and paying for travel for his “KGB” network of helpers.

He maintained elaborate records, including a “Master Chart” of games, a Google calendar of assignments, and “game day sheets” cataloging thousands of opponent signals. This was not a one-off corner-cutting; it was a fully designed intelligence apparatus.

For compliance officers, this resonates with what we see in corporate scandals: low-level staffers who are empowered and even celebrated for gaming the system, building shadow operations, and producing results that leadership quietly benefits until the scheme explodes into public view.

Beyond Scouting: Recruiting Inducements and Communications

The NCAA’s investigation did not stop at the scouting scheme. It also uncovered impermissible recruiting inducements and contacts. Assistant Coach Steve Clinkscale drove a recruit and his parents to dinner and paid for their meals, provided gear, and even tried to secure “blue check” Instagram verification for another recruit. Denard Robinson, a Michigan football legend turned staffer, also handed out bags of gear. Other inducements included charitable donations to the family of a recruit.

In another violation, Assistant Coaches Jesse Minter and Chris Partridge exchanged nearly 100 impermissible text messages with a prospect before the allowable date. The rules here are clear: no electronic communication until a prospect’s junior year. Yet the coaches went forward anyway, later excusing themselves as “confused about the player’s age”.

Again, this will sound familiar to compliance officers. How many corporate bribery cases involve “hospitality” that turns into improper meals or “business development” that is, in fact, disguised inducement? How many sales managers try to explain away improper payments by claiming they misunderstood the rules?

Leadership Failures: Jim Harbaugh’s Responsibility

The NCAA placed significant responsibility on then-Head Coach (and now San Diego Charger Head Coach) Jim Harbaugh. Under NCAA rules, the head coach is presumed responsible for creating a culture of compliance and monitoring staff. Harbaugh failed in both respects. The decision was blunt: “Harbaugh did not embrace that responsibility. Harbaugh and his program had a contentious relationship with Michigan’s compliance office, leading coaches and staff members to act, at times, with disregard for the rules”.

In practice, this meant Harbaugh either knew and ignored, or intentionally avoided knowing, what his staff was doing. As the record showed, staff referred to compliance as “true scum of the earth,” while Harbaugh awarded Stalions a game ball for his signal-stealing efforts. Whether or not he knew the full scope, the culture was one of indifference, if not hostility, to rules.

For corporate leaders, this is a textbook “tone at the top” failure. Regulators have made clear that leaders are responsible not only for their own conduct but for the culture they set. Harbaugh’s failure mirrors what the DOJ calls “failure to promote a culture of compliance.”

Failures to Cooperate and Obstruction

The misconduct did not stop when the NCAA came knocking. In fact, some of the most damning behavior occurred after the investigation began.

• Connor Stalions destroyed his phone and hard drives, bragging they were at the bottom of a pond. He instructed interns to delete texts, and even urged a student-athlete to “lie your ass off” to investigators.
• Jim Harbaugh refused to turn over phone records or sit for interviews once he left for the NFL.
• Sherrone Moore, then an assistant, deleted 52 text messages with Stalions the day the news broke. He later admitted it was an “emotional reaction”.
• Denard Robinson gave false or misleading answers about whether he handed out gear.

The NCAA viewed these failures to cooperate as Level I violations, some of the most serious possible. For compliance officers, the parallel is unmistakable. In corporate investigations, obstruction , destroying documents, deleting emails, misleading investigators,  is often what turns a bad case into a catastrophic one.

Repeat Violator Status

Perhaps the most damning aspect of this case was Michigan’s history. The 2025 case overlapped with a 2024 infractions decision, also involving the football program, where violations occurred during the COVID dead period. That case resulted in probation, recruiting restrictions, and suspensions. Now, less than a year later, Michigan was back before the Committee on Infractions. As a result, both the university and Harbaugh were deemed repeat violators (recidivists in the compliance world), triggering higher penalties.

For compliance professionals, this is the equivalent of a company that resolves an FCPA matter, pledges reform, and then shows up again within five years. Regulators view such behavior harshly. Once you’ve been given a chance to reform, repeated violations suggest systemic problems and leadership indifference.

The NCAA’s Case Summary

To summarize the background facts:

• Impermissible scouting: 56 instances of in-person, off-campus scouting across three seasons.
• Recruiting inducements: meals, gear, transportation, and social media favors for prospects.
• Improper communications resulted in nearly 100 premature text messages.
• Leadership failures: Harbaugh’s lack of responsibility and tone at the top.
• Failures to cooperate: destruction of evidence, deletions, and false statements.
• Repeat violator status: back-to-back major infractions cases within two years.

As with an SEC or DOJ enforcement action, the facts reveal a program where non-compliance was not incidental but systemic, and where leadership did little to prevent or even detect misconduct.

Why Compliance Professionals Should Care

At first glance, one might dismiss this as a sports story. But for compliance officers, this case is highly instructive. It demonstrates:

• How schemes are often run by ambitious “low-level” staff but tolerated at higher levels.
• How small inducements such as meals, gear, favors can constitute serious violations.
• How leadership failures define culture.
• How obstruction magnifies penalties.
• How repeat violations eliminate credibility with regulators.

These are not just lessons for athletics; they are lessons for corporate compliance across industries. The University of Michigan football infractions case offers a rich factual record, but facts alone do not explain why violations occurred. For that, we must examine the culture.

In Part 2 of this series, I will explore how the Michigan football program created an environment where compliance was unwelcome, resisted, and actively undermined. As the NCAA decision made clear, the Chief Compliance Officer did everything she could — but the culture of football won the day. For compliance professionals, that is the heart of the story: the facts expose the violations, but the culture explains them.

Ed. Note: As most of my readers know, I am a UM Law graduate. Now we have UM winning a National Championship, the same year they were cheating in college football games. Did its cheating help win games? About as much as the Houston Astros’ trash can beating, sign-stealing did to help them win the AL Pennant back in 2017. I went to the University of Texas for my undergraduate degree, and now all I need for UT to become embroiled in a cheating scandal the first year they will win the National Championship since Vince Young and the win over USC in 2006, and I will have the trifecta of my teams cheating to win ‘the Big One’. (I am also a huge Dallas Cowboys fan, but there is no chance the Cowboys will ever win a championship as long as Jerry Jones runs the club, so no worries, Cowboy cheating and about moving to a Quad.)