MENTAL HEALTH AS AN INJURY: RETHINKING INSTITUTIONAL LIABILITY IN COLLEGE ATHLETICS
Author: Molly Glass, Senior Editor
Introduction
Suicide has been reported as the second leading cause of death among young adults.[i] For collegiate athletes specifically, suicide rates doubled between 2002 and 2022.[ii] Despite growing mental health concerns, most Division I athletic departments still lack adequate mechanisms to address the needs of student-athletes.[iii] Although the NCAA has taken steps to prioritize student-athlete well-being, gaps remain between existing initiatives and reported needs.[iv]
A 2025 research publication revealed that while all NCAA Division I institutions participating in the study reported providing some form of mental health service, only 22% offered access to a psychiatrist.[v] While the NCAA has highlighted the importance of this issue, research on the availability of mental health professionals in collegiate athletics is limited, though growing.[vi] This disparity reflects an increasing concern over the adequacy of the mental health services available to student-athletes. The gravity of these risks is illustrated in Meyer v. Leland Stanford University (“Katie Meyer case”).[vii]
Katie Meyer, the Stanford women’s soccer captain and star goalie, died by suicide in 2022.[viii] In February 2022, Katie received a disciplinary notice from Stanford’s Office of Community Standards that placed her diploma on hold and threatened her removal from the school.[ix] The plaintiffs claimed that despite Katie expressing distress over this threat, Stanford employees made no effort to ensure her well-being.[x] The case was settled out of court in January 2026, which included an agreement for Stanford and the Meyer family to work together to launch an initiative focused on mental health and well-being of student-athletes.[xi]
Claims arising from student-athletes’ mental health concerns are most appropriately evaluated under a negligence standard,[xii] where the person bringing the claim must establish that the school owed a duty of care to the student[xiii] and that the school violated this duty.[xiv] When evaluating these claims, courts frequently weigh the burden of taking precautions against the probability and severity of harm.[xv] Colleges owe a duty of care to their athletes, a duty that rises significantly when suicide is at issue. Yet the widespread inadequacy of mental health resources in college athletics programs highlights that institutions are falling short of that heightened standard, leaving them legally vulnerable when that failure is challenged.
The NCAA’s Duty to Athletes
The NCAA was founded to promote the safety and well-being of student-athletes, with the stated goal of protecting their mental and physical health.[xvi] Courts have recognized this by holding that schools owe a heightened duty to recruited athletes when their injury stems from the sport they were recruited for.[xvii] This heightened duty logically extends to mental health risks, which are increasingly inherent in collegiate athletics. The NCAA has acknowledged this by expanding the mental health services offered to athletes.[xviii]
In Kleinknecht v. Gettysburg College, the Third Circuit recognized that a special relationship exists between a recruited student-athlete and the college.[xix] The court emphasized that because life-threatening injuries are reasonably foreseeable in contact sports, the college had a duty to take reasonable precautionary measures.[xx] This reasoning should not be confined to physical injuries, as the pressures inherent in collegiate athletics make mental health risks equally foreseeable. The Katie Meyer case illustrates this point.[xxi]
In the Katie Meyer case, the school was on notice that she was in distress, yet made no effort to ensure her well-being.[xxii] This failure demonstrates that mental health risks for student-athletes are not only foreseeable but demand institutional action. In response to her death, the California Legislature passed Katie Meyer’s Law.[xxiii] The law mandates that any California college or university receiving public funding for financial aid have a designated adviser during disciplinary proceedings.[xxiv]
Therefore, though the law has long recognized that colleges owe a duty to protect their athletes from foreseeable harm, this duty should encompass mental health. As mental health risks continue to grow within college athletics, the law must evolve to meet these needs, particularly given the overall lack of mental health support offered by those colleges.
Not Protecting an Athlete’s Mental Health is a Breach of Duty
Breach is frequently evaluated by weighing the burden of taking precautions against the probability of loss and the gravity of probable loss.[xxv] In cases where mental health is the injury being evaluated, particularly in cases of suicide, the gravity of probable loss is extreme.[xxvi] Additionally, assessing the probability of loss requires examining what the institution knew about the student’s condition and whether it responded accordingly.[xxvii] In the case of Schieszler v. Ferrum College, the court applied this standard.[xxviii]
In 2000, Michael Frentzel (“Frentzel”) died by suicide in his dorm room at Ferrum College.[xxix] Despite expressing distress, self-inflicting injuries, and threatening suicide, the school took no action to assist him.[xxx] The court found that Ferrum College’s awareness of Frentzel’s struggles established an imminent probability of harm and a duty to mitigate that risk based on his individualized circumstances.[xxxi]
This reasoning applies to NCAA institutions with even greater force. Unlike Ferrum College, which had limited involvement in Frentzel’s everyday life, NCAA programs have a degree of involvement with student-athletes that extends far beyond that of an average student. Student-athletes are recruited and monitored by staff daily, giving institutions both the awareness of and the ability to address mental health risks before they escalate.
The type and availability of mental health services can serve as evidence of whether an institution has exercised reasonable care in fulfilling its duty to student-athletes. Industries such as law enforcement and the military have increasingly recognized that foreseeable mental health risks demand institutional safeguards.[xxxii] When an NCAA institution lacks adequate services to address a student-athlete’s needs, the probability of loss increases substantially.[xxxiii] The burden of implementing reasonable measures, however, is minimal compared to the irreversible consequences of suicide.[xxxiv] Given that only 22% of Division I institutions offer access to a psychiatrist, the gap between services needed and those available serves as evidence that many programs fall short of meeting this reasonable care standard.[xxxv]
Moving Forward
Enforcing a negligence standard compels institutions to re-evaluate how they provide proper care to student-athletes. Holding institutions accountable for reasonable safeguards encourages proactive intervention, ensuring that student-athletes receive the support they need before preventable tragedies occur, like Katie Meyer’s death.
[i] Bridget M. Whelan et al., Suicide in National Collegiate Athletic Association Athletes: A 20 Year Analysis, Brit. J. Sports Med. (Apr. 4, 2024).
[ii]Id.; Study: Suicide Among College Athletes Doubled in 20 Years, UW Med. Newsroom (Apr. 4, 2024), https://newsroom.uw.edu/news-releases/study-suicides-among-college-athletes-doubled-in-20-years.
[iii] Matthew Jones et al., Mental Performance and Mental Health Services in NCAA D1 Athletic Departments, 2 J. Advancing Sports Psych. Res. 4 (2022).
[iv] National Collegiate Athletic Ass’n, Mental Health, NCAA (2021), https://www.ncaa.org/sports/2021/2/10/sport-science-institute-mental-health.aspx.
[v] Emily R. Strouphauer et al., Access to Sports Psychiatrists and Specialized Mental Health Services for NCAA Division I Athletes, Sports Psych (2025).
[vi] See Jones, supra note iii.
[vii] Complaint, Meyer v. Leland Stanford Junior Univ., No. 22CV407844 (Cal. Super. Ct. Nov. 2022), https://www.documentcloud.org/documents/23320591-meyer-v-stanford-complaint.
[viii]Id. ¶¶ 2, 47.
[ix]Id. ¶ 8; see also id. ¶¶ 7, 181.
[x]Id. ¶¶ 13–16.
[xi]Stanford Settles Wrongful Death Suit with Katie Meyer’s Family, Announces Mental Health Initiative, AP (Jan. 27, 2026).
[xii] Legal Info. Inst.,Negligence,Cornell L. Sch., https://www.law.cornell.edu/wex/negligence.
[xiii]Id.
[xiv]Id.
[xv]United States v. Carroll Towing Co., 159 F.2d 169 (2d Cir. 1947).
[xvi]See National Collegiate Athletic Ass’n, supra note iv.
[xvii]Kleinknecht v. Gettysburg Coll., 989 F.2d 1360, 1367 (3d Cir. 1993).
[xviii]See National Collegiate Athletic Ass’n, supra note iv; Christian Dalton-Locke et al., The Effectiveness of Mental Health Rehabilitation Services: A Systematic Review and Narrative Synthesis, 11 Frontiers Psychiatry (2021), https://pmc.ncbi.nlm.nih.gov/articles/PMC7838487.
[xix]Kleinknecht, 989 F.2d at 1366–67.
[xx]Id. at 1370
[xxi]See Complaint, Meyer, No. 22CV407844, ¶¶ 13–16.
[xxii]Id.
[xxiii] Cal. Educ. Code § 66283 (2024) (Katie Meyer's Law); Xuan Thai, Stanford, Family of Katie Meyer Settle Wrongful Death Lawsuit, ESPN (Jan. 26, 2026).
[xxiv]Id.
[xxv]SeeCarroll Towing Co., 159 F.2d at 173.
[xxvi]See Whelan, supra note i.
[xxvii]See Schieszler v. Ferrum College, 236 F. Supp. 2d 602, 609 (W.D. Va. 2002).
[xxviii]Id.
[xxix]Id. at 605.
[xxx]Id. at 606.
[xxxi]Id. at 609.
[xxxii]See 10 U.S.C. § 1074m; Mandatory Mental Health Visits, Community Policing Dispatch (Mar. 2023), https://cops.usdoj.gov/html/dispatch/03-2023/mental_health_visits.html.
[xxxiii]See Dalton-Locke, supra note xviii.
[xxxiv]Id.
[xxxv]See Strouphauer et al., supra note v.