STATEMENT OF THE CASE

University of Mississippi – Case No. 00561

July 21, 2017

TABLE OF CONTENTS

I. BRIEF HISTORY (CASE CHRONOLOGY) ................................................................................. 1

II. ALLEGATION NO. 1 – Saunders and Vaughn engaged in ACT exam fraud on behalf
of and [NCAA Division I Manual Bylaws 10.01.1, 10.1 and
10.1-(h) (2009-10); 14.1.2, 14.3.2.1, 14.3.2.1.1 and 15.01.5 (2010-11); 14.11.1 (2010-
11 through 2012-13); and 14.10.1 (2013-14)] ................................................................................. 5

III. ALLEGATION NO. 2 – Saunders, Vaughn and Nix arranged for Thigpen to provide
impermissible housing, meals and transportation to
and [NCAA Division I Manual Bylaws 10.01.1, 10.1, 10.1-
(c), 13.01.4, 13.1.2.1, 13.2.1, 13.2.1.1-(h) and 13.15.1 (2009-10); 14.11.1 (2010-11
through 2012-13); and 14.10.1 (2013-14)] ...................................................................................... 6

IV. ALLEGATION NO. 3 – Vaughn violated the cooperative principle and knowingly
provided false or misleading information regarding Allegation No. 1. [NCAA Division
I Manual Bylaws 10.01.1, 10.1, 10.1-(d), 19.2.3 and 19.2.3.2 (2013-14)] ...................................... 8

V. ALLEGATION NO. 4 – Saunders knowingly provided false or misleading information
regarding Allegation No. 1. [NCAA Division I Manual Bylaws 10.01.1, 10.1 and 10.1-
(d) (2013-14)] .................................................................................................................................. 9

VI. ALLEGATION NO. 5 – Hughes made impermissible recruiting contact with and
provided various impermissible recruiting inducements to
and M. Harris knew of and at times facilitated Hughes' recruiting activities
and arranged impermissible hotel lodging for and [NCAA
Division I Manual Bylaws 11.7.2.2, 13.01.4, 13.1.2.1, 13.1.2.4-(a), 13.1.2.5,
13.1.3.5.1, 13.2.1, 13.2.1.1-(b), 13.2.1.1-(e), 13.5.3, 13.7.2.1 and 13.7.2.1.2 (2012-13)]
....................................................................................................................................................... 10

VII. ALLEGATION NO. 6 – The football program produced and/or played impermissible
personalized recruiting videos and did so with Freeze's knowledge and approval.
[NCAA Division I Manual Bylaws 13.4.1.5 and 13.6.7.9 (2012-13)] ........................................... 12

VIII. ALLEGATION NO. 7 – The football program arranged impermissible hunting trips
for on land owned by a booster. [NCAA Division I Manual Bylaws 13.2.1 and
13.6.7.1 (2012-13); 16.11.2.1 (2013-14)] ...................................................................................... 13

IX. ALLEGATION NO. 8 – Kiffin arranged impermissible hotel lodging and meals for
family members who were not parents or legal guardians of during his official
paid visit. [NCAA Division I Manual Bylaws 13.2.1, 13.6.7.7 and 13.6.8 (2012-13)] ................. 14

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STATEMENT OF THE CASE
Table of Contents
Case No. 00561
July 21, 2017
__________

X. ALLEGATION NO. 9 – Kiffin arranged impermissible merchandise for and
Farrar did so for and [NCAA Division I Manual Bylaws 13.2.1,
13.2.1.1-(b) and 13.2.1.1-(f) (2012-13, 2013-14 or 2014-15 and 2015-16)] ................................. 15

XI. ALLEGATION NO. 10 – Kiffin provided impermissible lodging at his residence to
[NCAA Division I Manual Bylaw 16.11.2.1 (2012-13)] ................................................... 16

XII. ALLEGATION NO. 11 – Patel provided impermissible lodging to and
[NCAA Division I Manual Bylaw 16.11.2.1 (2012-13 and 2013-14] ............................. 17

XIII. ALLEGATION NO. 12 – Freeze made impermissible recruiting contact with
[NCAA Division I Manual Bylaw 13.1.1.1 (2013-14)] ................................................................. 18

XIV. ALLEGATION NO. 13 – Kiffin made impermissible recruiting contact with and
[NCAA Division I Manual Bylaw 13.1.1.1 (2013-14)] ................................................... 19

XV. ALLEGATION NO. 14 – Farrar arranged impermissible transportation and/or hotel
lodging for and and friends and family. Additionally, the
football program provided impermissible meals to these individuals. [NCAA Division
I Manual Bylaws 13.1.2.1, 13.1.2.5, 13.2.1, 13.5.3, 13.7.2.1 and 13.7.2.1.2 (2013-14
and 2014-15); and 13.6.7.7 and 13.6.8 (2014-15)] ........................................................................ 20

XVI. ALLEGATION NO. 15 – L. Harris provided impermissible cash payments to
and impermissible food and drinks to and his friends and family. [NCAA
Division I Manual Bylaws 13.2.1 and 13.2.1.1-(e) (2013-14 and/or 2014-15)] ............................ 22

XVII. ALLEGATION NO. 16 – and engaged in impermissible recruiting contact
and communication with and provided with impermissible cash
payments. Additionally, Farrar initiated and facilitated and recruiting
contact and communication of and knew at the time that they provided him with
cash payments. [NCAA Division I Manual Bylaws 11.7.2.2 (2013-14); 13.1.2.1,
13.1.2.4-(a), 13.1.2.5 and 13.1.3.5.1 (2013-14 and 2014-15); 13.2.1 and 13.2.1.1-(e)
(2013-14 and/or 2014-15)]............................................................................................................. 23

XVIII. ALLEGATION NO. 17 – Farrar knowingly committed violations of NCAA legislation
and knowingly provided false or misleading information regarding Allegation Nos. 14
and 16. [NCAA Division I Manual Bylaws 10.01.1, 10.1 and 10.1-(c) (2013-14, 2014-
15 and 2016-17)] ............................................................................................................................ 24

XIX. ALLEGATION NO. 18 – Strojny provided an impermissible cash payment to
[NCAA Division I Manual Bylaw 16.11.2.1 (2014-15)] ................................................... 26

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STATEMENT OF THE CASE
Case No. 00561
July 21, 2017
Page No. 1

I. BRIEF HISTORY (CASE CHRONOLOGY)

April 2010 – The institution hired David Saunders (Saunders) as administrative operations
coordinator for football.

May and June 2010 – Saunders and Chris Vaughn (Vaughn), then assistant football coach and
recruiting coordinator, engaged in fraudulence or misconduct in connection with the June 2010
ACT exams taken by then football prospective student-athletes (
( and ( (Allegation No. 1).

Summer of 2010 – Saunders, Vaughn and Derrick Nix (Nix), assistant football coach, arranged
for then football prospective student-athletes (
( ( and to live with Darel Thigpen
(Thigpen), then representative of the institution's athletics interests, while enrolled in summer
courses in Jackson, Mississippi (Allegation No. 2).

2010-11 academic year – and practiced, competed and received
athletically related financial aid while ineligible (Allegation Nos. 1 and 2).

2011-12 through 2012-13 academic years – and competed while
ineligible (Allegation Nos. 1 and 2).

December 5, 2011 – The institution hired Hugh Freeze (Freeze) as head football coach.

October 2012 to March 2013 –Walter Hughes (Hughes), then representative of the institution's
athletics interests, engaged in impermissible activities in recruiting then football prospective
student-athletes ( (
( and ( and Maurice Harris (M. Harris), assistant football
coach and recruiting coordinator, facilitated Hughes' involvement and arranged free hotel
lodging for and (Allegation No. 5).

October 17, 2012 – The NCAA enforcement staff issued a verbal notice of inquiry to the
institution in Case No. 189693 regarding potential violations in women's basketball.

January to February 2013 – The football program made impermissible recruiting videos
(Allegation No. 6); the football program arranged an impermissible hunting trip for then
football prospective student-athlete ( (Allegation No. 7); Chris Kiffin
(Kiffin), then assistant football coach, arranged impermissible hotel lodging and meals in
conjunction with then football prospective student-athlete ( official
paid visit (Allegation No. 8); and Kiffin arranged for ( then boyfriend
to mother, ( to receive free merchandise from Rebel Rags,
LLC (Rebel Rags) (Allegation No. 9).
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Case No. 00561
July 21, 2017
Page No. 2

February 2013 – The enforcement staff's investigation expanded into football.

February to August 2013 – The institution and enforcement staff investigated issues detailed
in Allegation Nos. 5, 6 and 8.

March to May 2013, July to August 2015, February to March 2016, August 2016 to January
2017 – The enforcement staff and institution investigated issues detailed in Allegation No. 9.

Summer 2013 – Kiffin provided impermissible lodging to (Allegation No. 10).

June 2013 to May 2014 – Chan Patel (Patel), then representative of the institution's athletics
interests, provided impermissible lodging to and (Allegation No. 11).

August 2013 to December 2014 – The enforcement staff and institution investigated issues
detailed in Allegation Nos. 1 through 4.

August 14 to 31, 2013 – Vaughn communicated with individuals with knowledge of pertinent
facts of the enforcement staff's investigation (Allegation No. 3).

2013-14 academic year – competed while ineligible (Allegation No. 1).

December 3, 2013 – Freeze made impermissible, in-person recruiting contact with then football
prospective student-athlete ( (Allegation No. 12).

December 16, 2013, and February 25, 2014 – Saunders knowingly provided false or misleading
information to the enforcement staff and institution during interviews (Allegation No. 4).

December 17, 2013 – Vaughn knowingly provided false or misleading information to the
enforcement staff and institution during an interview (Allegation No. 3).

December 2013 to January 2014 – The football program arranged impermissible hunting trips
on land owned by a booster for then football student-athlete

March 2014 to February 2015 –Barney Farrar (Farrar), then assistant director for high school
and junior college relations, arranged for to receive free merchandise from Rebel Rags
(Allegation No. 9); Farrar arranged impermissible recruiting inducements for then football
prospective student-athlete ( and/or friends and family
(Allegation Nos. 14 and 17); Farrar initiated and facilitated impermissible recruiting contact of
by and , then representatives of the institution's
athletics interests, and knew and provided with cash payments (Allegation
Nos. 14, 16 and 17); and (4) Lee Harris (L. Harris), then representative of the institutions
STATEMENT OF THE CASE
Case No. 00561
July 21, 2017
Page No. 3

athletics interests, provided with cash payments and provided and his friends and
family with free food and drinks (Allegation No. 15).

May 8, 2014 – Kiffin made impermissible, in-person recruiting contact with then football
prospective student-athletes ( and ( (Allegation No.
13).

August 22, 2014 – Michael Strojny (Strojny), then representative of the institution's athletics
interests, provided $800 cash to (Allegation No. 18).

August 2014 to August 2015 – Cannon Motor Company (Cannon Motors), then representative
of the institution's athletics interests, provided then football student-athlete and football
student-athlete ( impermissible loaner vehicles. Additionally, Cannon
Motors and Michael Joe Cannon (Cannon), owner of Cannon Motors and then representative
of the institution's athletics interests, provided an impermissible $3,000 loan (Allegation
No. 19).

October to December 2014 – The enforcement staff and institution investigated issues detailed
in Allegation No. 13.

October 25 to December 31, 2014 – competed in six contests while ineligible
(Allegation No. 19).

July 1, 2015 – reported to the NCAA potential violations involving

July to September 2015 – The enforcement staff and institution investigated issues detailed in
Allegation Nos. 9, 10, 11, 18 and 19.

September 2015 to January 31, 2016 – Farrar arranged for then football prospective student-
athlete ( to receive free merchandise from Rebel Rags (Allegation No. 9).

January 22, 2016 – The enforcement staff issued a notice of allegations in Case No. 189693.

March 17, 2016 – The enforcement staff issued a verbal notice of inquiry to the institution in
Case No. 00561.

April 2016 – The enforcement staff's football development group began receiving information
of additional potential violations in football.

April 28, 2016 – Information surfaced regarding potential additional violations involving
that the enforcement staff and institution required additional time to investigate.
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Case No. 00561
July 21, 2017
Page No. 4

June 2, 2016 – The NCAA Division I Committee on Infractions bifurcated Case No. 189693,
severing the women's basketball and track and field portions of the case from the football
portion of the case.

June 8, 2016 – The enforcement staff issued a revised notice of allegations in Case No. 189693
that contained only the women's basketball and track and field allegations.

July 25, 2016 – The Committee on Infractions heard Case No. 189693.

Late July 2016 – The enforcement staff's football development group provided the investigative
team information of potential additional violations, including and

August 2016 to February 2017 – The enforcement staff and institution investigated issues
detailed in Allegation Nos. 7, 9, 12 and 14 through 17.

December 1, 2016 – Farrar knowingly provided false or misleading information to the
enforcement staff and institution (Allegation No. 17).

December 21, 2016 – Representatives from the institution and Southeastern Conference visited
the NCAA national office for a pre-notice of allegations conference.

February 22, 2017 – The enforcement staff issued a notice of allegations in Case No. 00561.

May 23, 2017 – The institution, Farrar, Freeze, M. Harris, Kiffin and Nix submitted their
responses to the notice of allegations.

June 1, 2017 – Vaughn submitted his response to the notice of allegations.

June 19, 2017 – The enforcement staff conducted a prehearing conference with the institution.

June 23, 2017 – The enforcement staff conducted a prehearing conference with Freeze.

June 28, 2017 – The enforcement staff conducted a prehearing conference with Vaughn.

July 5, 2017 – The enforcement staff conducted a prehearing conference with M. Harris.

July 6, 2017 – The enforcement staff conducted prehearing conferences with Nix and Farrar.

July 12, 2017 – The enforcement staff conducted prehearing conferences with Kiffin and
Saunders.

July 21, 2017 – The enforcement staff submitted its reply and statement of the case.
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Case No. 00561
July 21, 2017
Page No. 5

II. ALLEGATION NO. 1 – Saunders and Vaughn violated the principles of ethical conduct
when they engaged in fraudulence or misconduct in connection with the June 2010 ACT
exams of and [NCAA Division I Manual Bylaws 10.01.1, 10.1
and 10.1-(h) (2009-10); 14.1.2, 14.3.2.1, 14.3.2.1.1 and 15.01.5 (2010-11); 14.11.1 (2010-11
through 2012-13); and 14.10.1 (2013-14)]

Alleged Level of Allegation No. 1: Severe Breach of Conduct (Level I Violation).

A. Position of institution.

1. Position on the allegation.

The institution agrees the facts are substantially correct and violations of NCAA legislation occurred.

2. Position on the level of the violation.

The institution agrees the alleged violations are Level I.

B. Position of Saunders.

1. Position on the allegation.

Saunders did not submit a response to the notice of allegations, but denied knowledge of and/or

involvement in the alleged violations in his two interviews.

2. Position on the level of the violation.

Saunders did not address the level.

C. Position of Vaughn.

1. Position on the allegation.

Vaughn denies knowledge of and/or involvement in the alleged violations.

2. Position on the level of the violation.

Vaughn did not address the level.

D. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violations occurred as alleged.
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July 21, 2017
Page No. 7

B. Position of Saunders.

1. Position on the allegation.

Saunders did not submit a response to the notice of allegations but denied knowledge of and/or

involvement in the alleged violations in his two interviews.

2. Position on the level of the violation.

Saunders did not address the level.

C. Position of Vaughn.

1. Position on the allegation.

Vaughn denies knowledge of and/or involvement in the alleged violations.

2. Position on the level of the violation.

Vaughn did not address the level.

D. Position of Nix.

1. Position on the allegation.

Nix denies knowledge of and/or involvement in the alleged violations.

2. Position on the level of the violation.

Nix asserts that if he committed a violation, his culpability should be considered Level III.

E. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violations occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 2 is a severe breach

of conduct (Level I).
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Case No. 00561
July 21, 2017
Page No. 8

F. Remaining issues in Allegation No. 2.

1. Did Saunders knowingly arrange for Thigpen to provide free housing, meals and

transportation to and

2. Did Vaughn knowingly arrange for Thigpen to provide free housing, meals and

transportation to and

3. Did Nix assist in arranging for Thigpen to provide free housing, meals and

transportation to

4. What is the level of the alleged violations?

5. If the panel concludes Nix is culpable for violations, what is the level of his culpability?

6. Are the violations impermissible recruiting inducements or preferential treatment?

IV. ALLEGATION NO. 3 – Vaughn violated the cooperative principle when he
communicated with individuals with knowledge of pertinent facts regarding the
enforcement staff's investigation after being admonished multiple times to refrain from
doing so. Additionally, Vaughn violated the principles of ethical conduct when he
knowingly provided false or misleading information during his December 17, 2013,
interview regarding Allegation No. 1. [NCAA Division I Manual Bylaws 10.01.1, 10.1, 10.1-
(d), 19.2.3 and 19.2.3.2 (2013-14)]

Alleged Level of Allegation No. 3: Severe Breach of Conduct (Level I Violation).

A. Position of institution.

1. Position on the allegation.

The institution did not take a position regarding the alleged violations.

2. Position on the level of the violation.

The institution did not address the level.

B. Position of Vaughn.

1. Position on the allegation.

Vaughn denies knowledge of and/or involvement in the alleged violations.
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Case No. 00561
July 21, 2017
Page No. 9

2. Position on the level of the violation.

Vaughn did not address the level.

C. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violations occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 3 is a severe breach

of conduct (Level I).

D. Remaining issues in Allegation No. 3.

1. Did Vaughn violate the NCAA cooperative principle when he communicated with

individuals with knowledge of pertinent facts regarding the investigation after being

admonished multiple times to refrain from doing so?

2. Did Vaughn knowingly provide false or misleading information in his December 2013

interview when he denied knowledge of and/or involvement in the violations detailed

in Allegation No. 1?

V. ALLEGATION NO. 4 – Saunders violated the principles of ethical conduct when he
knowingly provided false or misleading information during his December 16, 2013, and
February 25, 2014, interviews regarding Allegation No. 1. [NCAA Division I Manual
Bylaws 10.01.1, 10.1 and 10.1-(d) (2013-14)]

Alleged Level of Allegation No. 4: Severe Breach of Conduct (Level I Violation).

A. Position of institution.

1. Position on the allegation.

The institution did not take a position regarding the alleged violations.

2. Position on the level of the violation.

The institution did not address the level.
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July 21, 2017
Page No. 10

B. Position of Saunders.

1. Position on the allegation.

Saunders did not submit a response to the notice of allegations, but denied knowledge of and/or

involvement in the alleged violations in his two interviews.

2. Position on the level of the violation.

Saunders did not address the level.

C. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violations occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 4 is a severe breach

of conduct (Level I).

D. Remaining issues in Allegation No. 4.

Did Saunders knowingly provide false or misleading information in his December 2013 and February

2014 interviews when he denied knowledge of and/or involvement in the violations detailed in Allegation

No. 1?

VI. ALLEGATION NO. 5 – Hughes made impermissible recruiting contact with, and
provided impermissible recruiting inducements to, and
Additionally, M. Harris knew of Hughes' association to the four prospects and
at times facilitated Hughes' recruiting activities. M. Harris also arranged impermissible
hotel lodging for and [NCAA Division I Manual Bylaws 11.7.2.2,
13.01.4, 13.1.2.1, 13.1.2.4-(a), 13.1.2.5, 13.1.3.5.1, 13.2.1, 13.2.1.1-(b), 13.2.1.1-(e), 13.5.3,
13.7.2.1 and 13.7.2.1.2 (2012-13)]

Alleged Level of Allegation No. 5: Severe Breach of Conduct (Level I Violation).
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Case No. 00561
July 21, 2017
Page No. 11

A. Position of institution.

1. Position on the allegation.

The institution generally agrees the facts are substantially correct and violations of NCAA legislation

occurred. However, it disputes certain facts detailed in Allegation Nos. 5-e, 5-h, 5-j, 5-m and 5-o.

2. Position on the level of the violation.

The institution agrees the alleged violations are Level I.

B. Position of M. Harris.

1. Position on the allegation.

M. Harris denies facilitating Hughes' involvement in the four prospects' recruitment or knowing at the

time that Hughes was providing them with impermissible inducements. M. Harris also incorporates the

institution's disagreements regarding Allegation Nos. 5-e, 5-h, 5-j, 5-m and 5-o.

2. Position on the level of the violation.

M. Harris believes his culpability for the alleged violations is not Level I.

C. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violations occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 5 is a severe breach

of conduct (Level I).

D. Remaining issues in Allegation No. 5.

1. Did M. Harris facilitate Hughes' involvement in the football program's recruitment of

and
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Case No. 00561
July 21, 2017
Page No. 12

2. Did Hughes' presence for a portion of in-home recruiting visit by Freeze and

M. Harris, as detailed in Allegation No. 5-e, constitute a violation?

3. Did M. Harris arrange impermissible recruiting contact of and by

T. Scott and other football staff as detailed in Allegation No. 5-h? Relatedly, did M.

Harris know at the time the contact had occurred?

4. Did M. Harris arrange for and to stay in a hotel room the

institution provided for official paid visit as detailed in Allegation No.

5-j? Relatedly, was on an official paid visit or unofficial visit on this

occasion?

5. Did M. Harris arrange for to stay in a hotel room the institution provided

to family for official paid visit as detailed in Allegation No. 5-m?

6. Did Freeze know at the time that Hughes and/or Hughes' family was providing

academic tutoring assistance as detailed in Allegation No. 5-o?

7. If the hearing panel concludes M. Harris is culpable for violations, what is the level of

his culpability?

VII. ALLEGATION NO. 6 – The football program produced and/or played impermissible
personalized recruiting videos on three occasions and did so with Freeze's knowledge and
approval. [NCAA Division I Manual Bylaws 13.4.1.5 and 13.6.7.9 (2012-13)]

Alleged Level of Allegation No. 6: Breach of Conduct (Level III violation).

A. Position of institution.

1. Position on the allegation.

The institution agrees the facts are substantially correct and violations of NCAA legislation occurred.

However, it asserts Freeze has no culpability for the violations and naming him was unfairly prejudicial

and procedurally improper.
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Case No. 00561
July 21, 2017
Page No. 13

2. Position on the level of the violation.

The institution agrees the alleged violations are Level III.

B. Position of Freeze.

1. Position on the allegation.

Freeze agrees the facts are substantially correct and violations occurred but disagrees he is culpable.

2. Position on the level of the violation.

Freeze agrees the alleged violations are Level III.

C. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violations occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 6 is a breach of

conduct (Level III).

D. Remaining issues in Allegation No. 6.

Does the factual information substantiate culpability by Freeze for these violations?

VIII. ALLEGATION NO. 7 – The football program arranged impermissible hunting trips for
on land owned by a booster. [NCAA Division I Manual Bylaws 13.2.1 and 13.6.7.1
(2012-13); 16.11.2.1 (2013-14)]

Alleged Level of Allegation No. 7: Breach of Conduct (Level III).

A. Position of institution.

1. Position on the allegation.

The institution agrees the facts are substantially correct and violations of NCAA legislation occurred.

2. Position on the level of the violation.

The institution agrees the alleged violations are Level III.
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July 21, 2017
Page No. 14

B. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violations occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 7 is a breach of

conduct (Level III).

C. Remaining issues in Allegation No. 7.

None.

IX. ALLEGATION NO. 8 – Kiffin arranged impermissible hotel lodging and meals for family
members who were not parents or legal guardians of [NCAA Division I Manual
Bylaws 13.2.1, 13.6.7.7 and 13.6.8 (2012-13)]

Alleged Level of Allegation No. 8: Significant Breach of Conduct (Level II Violation).

A. Position of institution.

1. Position on the allegation.

The institution agrees the facts are substantially correct and violations of NCAA legislation occurred.

2. Position on the level of the violation.

The institution believes the alleged violations are Level III.

B. Position of Kiffin.

1. Position on the allegation.

Kiffin agrees the facts are substantially correct and violations of NCAA legislation occurred.

2. Position on the level of the violation.

Kiffin believes the alleged violations are Level III.
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July 21, 2017
Page No. 15

C. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violations occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 8 is a significant

breach of conduct (Level II).

D. Remaining issues in Allegation No. 8.

What is the level of the alleged violations?

X. ALLEGATION NO. 9 – Kiffin arranged free merchandise from Rebel Rags for
and Farrar did so for and [NCAA Division I Manual Bylaws 13.2.1,
13.2.1.1-(b) and 13.2.1.1-(f) (2012-13, 2013-14 or 2014-15 and 2015-16)]

Alleged Level of Allegation No. 9: Severe Breach of Conduct (Level I Violation).

A. Position of institution.

1. Position on the allegation.

The institution disagrees the facts are substantially correct or violations of NCAA legislation occurred.

2. Position on the level of the violation.

The institution did not address the level.

B. Position of Farrar.

1. Position on the allegation.

Farrar denies knowledge of and/or involvement in this allegation.

2. Position on the level of the violation.

Farrar did not address the level.
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July 21, 2017
Page No. 16

C. Position of Kiffin.

1. Position on the allegation.

Kiffin denies knowledge of and/or involvement in this allegation.

2. Position on the level of the violation.

Kiffin did not address the level.

D. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violations occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude Allegation No. 9 is a severe breach of

conduct (Level I).

E. Remaining issues in Allegation No. 9.

1. Did Kiffin arrange for to receive approximately $400 worth of free

merchandise from Rebel Rags during January 2013 official paid visit?

2. Did Farrar arrange for to receive approximately $400 worth of free merchandise

from Rebel Rags during a recruiting visit to the institution between March 28, 2014,

and January 25, 2015?

3. Did Farrar arrange for to receive approximately $2,000 worth of free

merchandise from Rebel Rags over four recruiting visits to the institution between

September 4, 2015, and January 31, 2016?

XI. ALLEGATION NO. 10 – Kiffin provided impermissible lodging at his residence to
[NCAA Division I Manual Bylaw 16.11.2.1 (2012-13)]

Alleged Level of Allegation No. 10: Breach of Conduct (Level III).
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July 21, 2017
Page No. 17

A. Position of institution.

1. Position on the allegation.

The institution agrees the facts are substantially correct and a violation of NCAA legislation occurred.

2. Position on the level of the violation.

The institution agrees the alleged violation is Level III.

B. Position of Kiffin.

1. Position on the allegation.

Kiffin agrees the facts are substantially correct and a violation of NCAA legislation occurred.

2. Position on the level of the violation.

Kiffin agrees the alleged violation is Level III.

C. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violation occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 10 is a breach of

conduct (Level III).

D. Remaining issues in Allegation No. 10.

None.

XII. ALLEGATION NO. 11 – Patel provided impermissible lodging to and
[NCAA Division I Manual Bylaw 16.11.2.1 (2012-13 and 2013-14)]

Alleged Level of Allegation No. 11: Severe Breach of Conduct (Level I Violation).

A. Position of institution.

1. Position on the allegation.

The institution agrees the facts are substantially correct and violations of NCAA legislation occurred.
STATEMENT OF THE CASE
Case No. 00561
July 21, 2017
Page No. 18

2. Position on the level of the violation.

The institution agrees the alleged violations are Level I.

B. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violations occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 11 is a severe breach

of conduct (Level I).

C. Remaining issues in Allegation No. 11.

None.

XIII. ALLEGATION NO. 12 – Freeze made impermissible in-person, off-campus recruiting
contact with [NCAA Division I Manual Bylaw 13.1.1.1 (2013-14)]

Alleged Level of Allegation No. 12: Breach of Conduct (Level III).

A. Position of institution.

1. Position on the allegation.

The institution disagrees the facts are substantially correct or that a violation of NCAA legislation

occurred.

2. Position on the level of the violation.

The institution did not address the level.

B. Position of Freeze.

1. Position on the allegation.

Freeze disagrees the facts are substantially correct or a violation of NCAA legislation occurred.

2. Position on the level of the violation.

Freeze did not address the level.
STATEMENT OF THE CASE
Case No. 00561
July 21, 2017
Page No. 19

C. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violations occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude Allegation No. 12 is a breach of conduct

(Level III).

D. Remaining issues in Allegation No. 12.

Did Freeze have impermissible in-person, off-campus recruiting contact with at

December 3, 2013?

XIV. ALLEGATION NO. 13 – Kiffin made impermissible in-person, off-campus recruiting
contact with and [NCAA Division I Manual Bylaw 13.1.1.1 (2013-14)]

Alleged Level of Allegation No. 13: Breach of Conduct (Level III).

A. Position of institution.

1. Position on the allegation.

The institution agrees the facts are substantially correct and violations of NCAA legislation occurred.

2. Position on the level of the violation.

The institution agrees the alleged violations are Level III.

B. Position of Kiffin.

1. Position on the allegation.

Kiffin agrees the facts are substantially correct and violations of NCAA legislation occurred.

2. Position on the level of the violation.

Kiffin agrees the alleged violations are Level III.
STATEMENT OF THE CASE
Case No. 00561
July 21, 2017
Page No. 20

C. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violations occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 13 is a breach of

conduct (Level III).

D. Remaining issues in Allegation No. 13.

None.

XV. ALLEGATION NO. 14 – Farrar arranged impermissible transportation and/or hotel
lodging for and friends and family. Additionally, the football
program provided these individuals with impermissible meals. [NCAA Division I Manual
Bylaws 13.1.2.1, 13.1.2.5, 13.2.1, 13.5.3, 13.7.2.1 and 13.7.2.1.2 (2013-14 and 2014-15); and
13.6.7.7 and 13.6.8 (2014-15)]

Alleged Level of Allegation No. 14: Severe Breach of Conduct (Level I Violation).

A. Position of institution.

1. Position on the allegation.

The enforcement staff and institution agree the facts regarding Allegation Nos. 14-a through 14-d, 14-

h and 14-i are substantially correct and violations of NCAA legislation occurred. The institution disagrees

with the facts regarding Allegation Nos. 14-e, 14-f and 14-g.

2. Position on the level of the violation.

The institution agrees the alleged violations are Level I.

B. Position of Farrar.

1. Position on the allegation.

Farrar agrees the facts regarding Allegation Nos. 14-b and 14-d concerning transportation are

substantially correct and violations occurred as well as acknowledges responsibility for the portions of
STATEMENT OF THE CASE
Case No. 00561
July 21, 2017
Page No. 21

Allegation No. 14 concerning meals. However, Farrar disagrees with the facts regarding Allegation No. 14-

c concerning transportation and Allegation Nos. 14-d through 14-i concerning hotel lodging.

2. Position on the level of the violation.

Farrar did not address the level.

C. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violations occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 14 is a severe breach

of conduct (Level I).

D. Remaining issues in Allegation No. 14.

1. Did Farrar arrange free transportation for in conjunction with a summer football

camp as detailed in Allegation No. 14-b?

2. Did Farrar arrange free transportation for in conjunction with a summer football

camp as detailed in Allegation No. 14-c?

3. Did Farrar arrange free transportation and hotel lodging for and as

detailed in Allegation No. 14-d? Relatedly, did Farrar arrange free transportation for

on this occasion?

4. Did Farrar arrange free hotel lodging for and in conjunction with an

unofficial visit as detailed in Allegation No. 14-e? Relatedly, did the football program

provide and with free meals on this occasion?
STATEMENT OF THE CASE
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July 21, 2017
Page No. 22

5. Did Farrar arrange free hotel lodging for and in conjunction with an

unofficial visit as detailed in Allegation No. 14-f? Relatedly, did the football program

provide and with free meals on this occasion?

6. Did Farrar arrange free hotel lodging for and in conjunction with an

unofficial visit as detailed in Allegation No. 14-g? Relatedly, did the football program

provide and with free meals on this occasion?

7. Did Farrar arrange free hotel lodging for and in

conjunction with an unofficial visit as detailed in Allegation No. 14-h?

8. Did Farrar arrange free hotel lodging for during official paid visit as

detailed in Allegation No. 14-i?

XVI. ALLEGATION NO. 15 – L. Harris provided impermissible cash payments to and
free food and drinks to and his friends and family. [NCAA Division I Manual Bylaws
13.2.1 and 13.2.1.1-(e) (2013-14 and/or 2014-15)]

Alleged Level of Allegation No. 15: Severe Breach of Conduct (Level I Violation).

A. Position of institution.

1. Position on the allegation.

The institution agrees and L. Harris had an in-person and telephone contact during his

recruitment. The institution also agrees and his companions received free food and drinks from L.

Harris' restaurant and bar on at least one occasion. However, the institution does not believe the facts

substantiate L. Harris provided the food and drinks or cash payments to and/or his companions.

2. Position on the level of the violation.

The institution did not address the level.
STATEMENT OF THE CASE
Case No. 00561
July 21, 2017
Page No. 23

B. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violations occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 15 is a severe breach

of conduct (Level I).

C. Remaining issues in Allegation No. 15.

Did L. Harris provide between $200 and $600 in impermissible cash payments to on two or three

occasions between March 28, 2014, and January 25, 2015? Relatedly, did L. Harris provide and his

companions with free food and drinks on these occasions?

XVII. ALLEGATION NO. 16 – and made impermissible recruiting contact with,
and provided impermissible cash payments totaling between $13,000 and $15,600 to
Additionally, Farrar initiated and facilitated and impermissible
recruiting contact with and knew at the time and provided cash
payments. [NCAA Division I Manual Bylaws 11.7.2.2 (2013-14); 13.1.2.1, 13.1.2.4-(a),
13.1.2.5 and 13.1.3.5.1 (2013-14 and 2014-15); 13.2.1 and 13.2.1.1-(e) (2013-14 and/or 2014-
15)]

Alleged Level of Allegation No. 16: Severe Breach of Conduct (Level I Violation).

A. Position of institution.

1. Position on the allegation.

The institution agrees the facts regarding Farrar initiating and facilitating and

impermissible recruiting contact with are substantially correct and that violations of NCAA

legislation occurred. However, the institution disagrees that the facts concerning and alleged

provision of cash payments to are substantially correct or that violations occurred.
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Case No. 00561
July 21, 2017
Page No. 24

2. Position on the level of the violation.

The institution believes the violations concerning and impermissible recruiting contact

of are Level II.

B. Position of Farrar.

1. Position on the allegation.

Farrar denies knowledge of and/or involvement in the alleged violations.

2. Position on the level of the violation.

Farrar did not address the level.

C. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violations occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 16 is a severe breach

of conduct (Level I).

D. Remaining issues in Allegation No. 16.

1. Did Farrar initiate and facilitate and impermissible recruiting contact of

2. Did and provide between $13,000 and $15,600 in impermissible

cash payments? If so, did Farrar know at the time and provided the

payments?

3. What is the level of the alleged violations?

XVIII. ALLEGATION NO. 17 – Farrar violated the principles of ethical conduct when he
knowingly committed violations of NCAA legislation and knowingly provided false or
misleading information regarding Allegation Nos. 14 and 16. [NCAA Division I Manual
Bylaws 10.01.1, 10.1 and 10.1-(c) (2013-14, 2014-15 and 2016-17)]
STATEMENT OF THE CASE
Case No. 00561
July 21, 2017
Page No. 25

Alleged Level of Allegation No. 17: Severe Breach of Conduct (Level I Violation).

A. Position of institution.

1. Position on the allegation.

The institution agrees the facts regarding Allegation Nos. 17-a, 17-c and 17-d are substantially correct

and that violations of NCAA legislation occurred. Additionally, the institution agrees the facts regarding

Allegation Nos. 17-b and 17-e, aside from the facts concerning impermissible cash payments, are

substantially correct and that violations occurred.

2. Position on the level of the violation.

The institution agrees the violations are Level I despite its disagreement regarding certain alleged facts.

B. Position of Farrar.

1. Position on the allegation.

Farrar denies knowledge of and/or involvement in the alleged violations.

2. Position on the level of the violation.

Farrar did not address the level.

C. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violations occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 17 is a severe breach

of conduct (Level I).

D. Remaining issues in Allegation No. 17.

1. Did Farrar knowingly arrange impermissible transportation and/or hotel lodging for

and
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Case No. 00561
July 21, 2017
Page No. 26

2. Did Farrar knowingly provide false or misleading information when he denied

knowledge of and/or involvement in arranging impermissible transportation for

in conjunction with recruiting visits to the institution, including visits in June, July and

August 2014?

3. Did Farrar knowingly provide false or misleading information when he denied

knowledge of and/or involvement in arranging free hotel lodging for in

conjunction with six unofficial visits to the institution between August 15 and

November 30, 2014?

4. Did Farrar knowingly initiate and facilitate impermissible recruiting contact and

communication of by and

5. Did Farrar know at the time that and provided with impermissible

cash payments?

6. Did Farrar knowingly provide false or misleading information when he denied

knowledge of and/or involvement in (1) arranging impermissible recruiting contact and

communication of by and and (2) and providing

with impermissible cash payments?

XIX. ALLEGATION NO. 18 – Strojny provided $800 cash to [NCAA Division I
Manual Bylaw 16.11.2.1 (2014-15)]

Alleged Level of Allegation No. 18: Severe Breach of Conduct (Level I Violation).

A. Position of institution.

1. Position on the allegation.

The institution agrees the facts are substantially correct and a violation of NCAA legislation occurred.

2. Position on the level of the violation.

The institution agrees the alleged violation is Level I.
STATEMENT OF THE CASE
Case No. 00561
July 21, 2017
Page No. 27

B. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violation occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 18 is a severe breach

of conduct (Level I).

C. Remaining issues in Allegation No. 18.

None.

XX. ALLEGATION NO. 19 – Cannon Motors provided impermissible complimentary vehicle
use to and Additionally, Cannon Motors and Cannon provided
with an impermissible $3,000 loan. [NCAA Division I Manual Bylaws 12.11.1 (2014-15);
16.11.2.1 (2014-15 and 2015-16); 16.11.2.2-(a) (2014-15); and 16.11.2.2-(c) (2014-15 and
2015-16)]

Alleged Level of Allegation No. 19: Severe Breach of Conduct (Level I Violation).

A. Position of institution.

1. Position on the allegation.

The institution agrees the facts are substantially correct and violations of NCAA legislation occurred.

2. Position on the level of the violation.

The institution agrees the alleged violations are Level I.

B. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violations occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 19 is a severe breach

of conduct (Level I).
STATEMENT OF THE CASE
Case No. 00561
July 21, 2017
Page No. 28

C. Remaining issues in Allegation No. 19.

None.

XXI. ALLEGATION NO. 20 – Freeze violated head coach responsibility legislation as he is
presumed responsible for the violations detailed in Allegation Nos. 5 through 10, 12
through 14, 16, 17-a and 17-b and failed to rebut that presumption. [NCAA Division I
Manual Bylaws 11.1.2.1 (October 13 through 29, 2012); 11.1.1.1 (October 30, 2012, through
2015-16)]

Alleged Level of Allegation No. 20: Severe Breach of Conduct (Level I Violation).

A. Position of institution.

1. Position on the allegation.

The institution disagrees the facts substantiate the alleged violation.

2. Position on the level of the violation.

The institution did not address the level.

B. Position of Freeze.

1. Position on the allegation.

Freeze disagrees the facts substantiate the alleged violation.

2. Position on the level of the violation.

Freeze did not address the level.

C. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violation occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 20 is a severe breach

of conduct (Level I).
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July 21, 2017
Page No. 29

D. Remaining issues in Allegation No. 20.

Did Freeze rebut the presumption of responsibility for the violations detailed in Allegation Nos. 5

through 10, 12 through 14, 16, 17-a and 17-b by demonstrating that he promoted an atmosphere of

compliance and monitored his staff?

XXII. ALLEGATION NO. 21 – The institution failed to exercise institutional control and
monitor the conduct and administration of its athletics program. [NCAA Constitution
2.1.1, 2.8.1 and 6.01.1 (2009-10 and 2011-12 through 2015-16); and NCAA Constitution 6.4.1
and 6.4.2 (2009-10 and 2012-13 through 2015-16)]

Alleged Level of Allegation No. 21: Severe Breach of Conduct (Level I Violation).

A. Position of institution.

1. Position on the allegation.

The institution disagrees the facts substantiate the alleged violation.

2. Position on the level of the violation.

The institution did not address the level.

B. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violation occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 21 is a severe breach

of conduct (Level I).

C. Remaining issues in Allegation No. 21.

Did the institution fail to demonstrate institutional control and monitor the conduct and administration

of its athletics program as evidenced by the violations detailed in Allegation Nos. 1, 2, 5 through 16, 17-a,

17-b and 18 through 20, and Finding Nos. IV-C and IV-H in Committee on Infractions Decision No. 460?