Louisiana Case Illustrates that Athletic Scholarships Are Not Guaranteed Contracts

By Gary J. Chester At a time when courts, state legislatures and even the NCAA are conferring more rights upon student-athletes, Holden v. Perkins, E.D. La. (Civil Action No. 20-2143, April 30, 2021), reminds us that an athletic scholarship is a precarious benefit. The Facts The plaintiff, Chloee Holden, received an athletic scholarship to play volleyball at Southeastern Louisiana University (SLU) for the academic year starting August 2016 and running through May 2017. The scholarship w