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The Business of College Football: Contracts, GMs, and the New Marketplace

 


Much has changed in college football since the first game between Princeton and Rutgers in 1869.[2] Since O’Bannon, Alston, and most recently the House settlement, college football has never been more like the National Football League ("NFL").[3] When the House settlement was approved on June 6, 2025, colleges gained the ability to directly compensate athletes up to a $20.5 million salary cap, which increases annually over a ten-year period.[4] Now, with the transfer portal, agents, contract negotiations, and roster management, college football programs have developed front offics that mirror those of the NFL.[5] 


The Rise of College Executives


One aspect that illustrates the professionalism of college football is the implementation of General Managers ("GM").[6] Over the last decade, the recruiting landscape has shifted dramatically with Name Image and Likeness ("NIL"), collectives, the transfer portal, and the elimination of scholarship limits alongside a salary cap.[7] Recruiting no longer centers around program tradition, player development, and educational opportunities, but rather financial incentives.[8] 


While major programs such as Texas A&M University, University of Alabama, University of Oklahoma, Ohio State University, and Stanford University have hired GMs to navigate this new era, the position itself is not entirely new.[9] What has changed, however, is the scope and responsibilities.[10] For example, in 2006 Georgia Tech hired Geoff Collins as the “Director of Player Personnel,” whose responsibilities included writing letters, making phone calls, managing the recruiting board, and acquiring game tape.[11] Fast forward to 2016, when Matt Dudeck became the first staff member in college football to hold the title of GM at the University of Arizona, where he was responsible for scholarship management, recruiting efforts, scouting, and managed the walk-ons and transfers.[12] Now, college GMs still perform many of the traditional duties once associated with player personnel roles.[13] However, their responsibilities have expanded to contract negotiation, communication with agents, salary cap management, compliance with NCAA and College Sports Commission’s ("CSC") regulations and state NIL laws, oversight of the transfer portal, and, in some cases, decision making authority over the entire program.[14] 


With these expanded responsibilities, athletic programs have begun investing heavily in executives with legal, financial, and professional sports backgrounds.[15] The University of North Carolina, for example, hired longtime NFL executive Michael Lombardi who has over 30 years of front office experience at an annual salary of $1.5 million.[16] Similarly, Alabama’s GM, Courtney Morgan, has experience working in athlete representation and contract negotiation at Vanguard Sports Group, earning $825,000 per year.[17] Brigham Young University ("BYU") has also followed this trend, hiring Dave George, a former lawyer, as its GM.[18] 


College Football Under Contracts


Historically, colleges and universities were barred from providing athletes with any form of compensation, relying instead on traditional recruiting methods that emphasized the opportunity to play professionally and receive a free education.[19] Following Alston, collectives emerged, allowing athletes to receive NIL compensation while the schools remained hands-off.[20] NIL collectives were independently formed organizations by alumni, boosters, and college supporters used to accumulate funds and create NIL opportunities for student-athletes.[21]  The House settlement marked another turning point, introducing the $20.5 million salary cap and enabling schools to negotiate directly with athletes, leading college football into the realm of contract law. [22]


Today, contracts, buyouts, and positional valuations dominate roster management.[23] GMs and programs are actively negotiating agreements with players that carry real-world legal and financial consequences.[24] From a contract law perspective, these agreements raise several legal questions concerning the enforceability and validity of their terms.[25] These contracts often include clauses governing guarantees, performance incentives, buyouts, and payment terms that resemble NFL contracts.[26]


The recent NIL and contract dispute between Madden Iamaleava and Arkansas highlights the uncertainty around damages and enforceability.[27] When Iamaleava enrolled at Arkansas in January of 2025, he reportedly signed a one-year, $500,000 contract with a collective called Arkansas EDGE.[28] The contract contained a clause that required Iamaleava to pay 50% of the remaining contract if he were to leave Arkansas prior to the completion of the one-year contract.[29] Just four months after signing, Madden transferred from Arkansas and followed his brother to UCLA.[30] Arkansas EDGE claims that Madden is contractually obligated to pay $200,000 of the remaining $400,000 despite never stepping on the field for the Razorbacks, raising questions around the liquidated damages clause.[31] However, for liquidated damages to be valid, the plaintiff must show that the damages sought are a reasonable estimate of the damages and not punitive.[32] In this instance, Arkansas EDGE would need to demonstrate non-speculative damages relating to lost marketing opportunities, licensing, or other tangible harms.[33] This highlights the broader challenges facing college GMs as they try to navigate the NIL landscape.


Another example of a contract and NIL dispute is the Florida-Rashada lawsuit.[34] In May 2024, Rashada filed a lawsuit against Florida’s head coach and a prominent Florida booster, alleging that false and fraudulent promises were made to Rashada, ultimately leading him to sign with the Gators.[35] Rashada, who was originally committed to another school had flipped his commitment to Florida where he agreed to a $13.85 million deal that was allegedly reneged on.[36] The dispute is heading to trial under claims of fraudulent misrepresentation and fraudulent inducement, aiding and abetting fraud, conspiracy to commit fraud, and negligent misrepresentation.[37] This illustrates how football programs and GMs must consider contractual implications and create clear, enforceable, and compliant contracts.[38] However, an interesting aspect of this case is that Rashada did not bring a reliance claim.[39] 

While both of these disputes’ pre-date the House settlement, they offer a glimpse of the contractual uncertainty that existed prior to direct athlete compensation. With the new layer of revenue sharing and direct school to athlete contracts, it will be interesting to see how future disputes evolve and how courts handle these unprecedented challenges. 


The New Marketplace


The transfer portal and revenue-sharing have also reshaped the economics of college football programs.[40] Gone are the days of simply providing a scholarship or a roster spot. GMs now manage multi-million-dollar budgets, allocating substantial sums to retain talent and limit departures.[41] During the 2024-2025 school year, nearly 5,000 FBS and more than 3,000 FCS players entered the transfer portal.[42] With the sheer number of players on the free market, GMs must allocate budgets efficiently and sign players according to their market values.[43] Recent reports suggest that starting caliber quarterbacks are being valued between $1-2 million, with elite recruits reaching up to $4 million.[44] Other positions vary; running backs range from $300,000-$700,000, wide-receivers from $400,000-$800,000, and offensive tackles and edge rushers from $500,000-$1,000,000.[45] 


Legal uncertainty around athlete contracts, their provisions, and enforceability adds another layer of complexity for programs.[46] At the same time, financial pressures and competition in the portal are forcing GMs to make high-stakes legal and financial decisions that have never been seen before in college athletics.[47]


Athletes as Employees


While college football is rapidly approaching a level of professionalism akin to that of the NFL, a major distinction still exists: NFL players are employees covered by a collective bargaining agreement ("CBA"), whereas college athletes are not recognized as employees and remain outside any formal labor structure.[48] The NFL’s CBA is a negotiated contract between the NFL and the National Football League Players Association ("NFLPA") that provides a framework for a wide range of topics such as player salaries, the length of a season, roster size, free agency, and health and safety - guardrails that college football currently lacks.[49] 


As more contract disputes are expected, the absence of standardized labor protections leaves both athletes and institutions exposed to legal uncertainty and inconsistent enforcement.[50] College football is a multi-billion-dollar enterprise operating under professional rules but without professional safeguards.[51] Serious conversations about collective bargaining, employee recognition, and standardized contracts are no longer theoretical. [52] They are essential to bringing order to a system that increasingly mirrors the NFL in every way but name. [53]


Ben Rosen (staff writer) is a 2L at Villanova University Charles Widger School of Law from Los Angeles, California. He graduated from Claremont McKenna College where he played four years of football and aspires to maintain a career in football. Currently, he is a co-external outreach chair as part of the Sports Law Society.



References:

[1] Photo by Steve DiMatteo on Unsplash.com (Jun 17,, 2021), (All rights reserved)

[2] Sam Richmond, 1st College Football Game Ever Was New Jersey vs. Rutgers in 1869, The NCAA (Nov. 6, 2023).

[3]David Broughton, Name, Image, Likeness Timeline, Sports Business Journal (Dec. 1, 2019).

[4] Dan Murphy, Judge OK’s $2.8B Settlement, Paving Way for Colleges to Pay Athletes, ESPN (Jun. 6, 2025).

[5]Jake Trotter and Max Olson, GM Position the New Gold Rush for College Football, ESPN (May 7, 2025).

[6] Shehan Jeyarajah, Tracking College Football GM Hires: Analyzing High-Profile Moves as Major Programs Prepare to Navigate New NIL Era, CBS Sports (Feb. 27, 2025).

[7] Meghan Durham White, DI Board of Directors Formally Adopt Changes to Roster Limits, NCAA (Jun. 23, 2025)

[8] Alex Schiffer, Michigan Flips No. 1 QB Bryce Underwood With Reported Eight-Figure NIL Deal, Front Office Sports (Nov. 22, 2024). (Demonstrating how recruiting in the NIL landscape has changed)

[9] Sam Khan Jr., The Evolution of the College Football General Manager, from Consigliere to Celebrity, The Athletic (Apr. 18, 2025).

[10] See Id. (Describing how the evolution of the GM role has evolved)

[11] See Id. (Describing how the evolution of the GM role has evolved)

[12] University of Arizona, University of Arizona Football Coaches and Staff, Matt Dudeck https://arizonawildcats.com/sports/football/roster/coaches/matt-dudek/249 (Demonstrating who the GM of Arizona is)

[13] Sam Khan Jr., Supra note 9. (Describing how the evolution of the GM role has evolved)

[14] See Id. (Describing how the evolution of the GM role has evolved)

[15] See Id. (Describing how the evolution of the GM role has evolved)

[16] See Id. (Describing how the evolution of the GM role has evolved)

[17] University of Alabama, University of Alabama Coaches and Staff, Courtney Morgan https://rolltide.com/sports/football/roster/staff/courtney-morgan/1385 (Demonstrating who the GM of Alabama is)

[18] Ryan McDonald, BYU Football Has Hired a New General Manager. Here’s Who it is and What the Role Will Entail, Yahoo Sports (Dec. 3, 2024) https://sports.yahoo.com/byu-football-hired-general-manager-004723975.html (Demonstrating who the GM of BYU is)

[19] Malaya Anaba, How NIL is Drastically Altering the College Recruiting Landscape, The Willistonian (Jan. 8, 2025).

[20] Laura C. Murray, The New Frontier of NIL Legislation, 60 Hous. L. Rev. 757 (2023). https://houstonlawreview.org/article/73674-the-new-frontier-of-nil-legislation (Evaluating the impact of the Alston decision)

[21] Curastory, What are NIL Collectives? (Feb. 14, 2023).

[22] Dan Murphy, Supra note 4. (Reporting Judge Wilken’s approval of the House Settlement)

[23] Dan Murphy, NIL Contracts Have Employment and Pay-for-Play All Over Them, Experts Say, ESPN (Mar. 5, 2025).

[24] See Id. (Analyzing how athlete contracts have employment terms)

[25] Phillip T. Sheng, Iamaleava v. Razorbacks: Are NIL Buyouts the Future of College Sports? Venable LLP (May 6, 2025).

[26] Richard Johnson, We Reviewed College Athlete Contracts – Here’s How Performance Adjustments, Buyouts and Bowl Incentives Work, CBS Sports (Jan. 31, 2025). (Describing what provisions are in NIL contracts)

[27] See Id. (Describing what provisions are in NIL contracts)

[28] See Id. (Describing what provisions are in NIL contracts)

[29] Phillip T. Sheng, Supra note 24. (Analyzing the dispute between Iamaleava and Arkansas)

[30] Richard Johnson, Supra note 25. (Describing what provisions are in NIL contracts)

[31] See Id. (Describing what provisions are in NIL contracts)

[32] Phillip T. Sheng, Supra note 24. (Analyzing the dispute between Iamaleava and Arkansas)

[33] See Id. (Analyzing the dispute between Iamaleava and Arkansas)

[34] ESPN, Jaden Rashada-Florida NIL Lawsuit: What to Know, What Comes Next, ESPN (May 21, 2024). https://www.espn.com/college-football/story/_/id/40190447/jaden-rashada-florida-gators-nil-lawsuit-next (Analyzing the dispute between Rashada and Florida)

[35] See Id. (Analyzing the dispute between Rashada and Florida)

[36] See Id. (Analyzing the dispute between Rashada and Florida)

[37] Matt Baker, Parts of Jaden Rashada Fraud Lawsuit Against Florida Coach Billy Napier Can Proceed, Judge Rules, The Athletic (Apr. 8, 2025).

[38] See Id. (Analyzing the dispute between Rashada and Florida)

[39] See Id.  (Analyzing the dispute between Rashada and Florida)

[40] Max Olson, College Football 2025: How Much Does Each Position Cost? ESPN (Aug. 24, 2025).

[41] See Id.  (Evaluating the marketplace values of college football positions)

[42] Max Olson, Why Did College Football Move its Transfer Portal? An FAQ, ESPN (Oct. 10, 2025).

[43] Max Olson, Supra note 39. (Evaluating the marketplace values of college football positions)

[44] See Id. (Evaluating the marketplace values of college football positions)

[45] See Id. (Evaluating the marketplace values of college football positions)

[46] Richard Johnson, Supra note 25. (Describing what provisions are in NIL contracts)

[47] See Id.  (Describing what provisions are in NIL contracts)

[48] Dan Graziano, NFL CBA Approved: What Players Get in New Deal, How Expanded Playoffs and Schedule Will Work, ESPN (Mar. 15, 2020).

[49] See Id. (Describing what provisions are in NIL contracts)

[50] See Id. (Describing what provisions are in NIL contracts)

[51] Ross Dellenger, Could Collective Bargaining be the Answer for College Sports? Some ADs are Ready to Say the Quiet Part Out loud, Yahoo Sports (Jun. 30, 2025).

[52] See Id. (Evaluating what a collective bargaining would look like in college sports)

[53] See Id.  (Evaluating what a collective bargaining would look like in college sports)


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