From Bets to Threats: The Impact of Murphy on Student-Athletes
The United States is experiencing a surge in the sports betting market following the Supreme Court’s 2018 decision to open the door for legalization.[1] College sports, a beloved tradition for decades, has only become more popular with the rise of social media, which allows fans to interact with the athletes directly without ever leaving their homes. Due to this accessibility and popularity, it is easy to see why sports betting and collegiate sports would go hand in hand. With the legalization of sports betting, fans are no longer just viewers of the game; they are investors. Fans can place proposition “prop” bets, which allows them to wager on specific aspects of an athlete’s performance.[2] However, because prop bets are directly tied to an athlete’s in-game performance, bettors may feel as though the student-athlete is personally responsible if they lose a bet. In some instances, this frustration has led fans to reach out to athletes directly via social media.[3] These students already face immense pressure trying to balance academic and athletic commitments, and now they must deal with the backlash from angry fans. Without social media, these fans would likely have no direct connection to the students at all. This new wave of harassment raises two questions: how did we get here, and who bears the responsibility for protecting student-athletes?
Background
The Professional and Amateur Sports Protection Act (PASPA) went into effect on January 1, 1993, with the purpose of stopping the spread of state-sanctioned or state-run sports gambling, maintaining the integrity of sports, and reducing the promotion of sports gambling among America’s youth.[4] The act prohibited all state-sanctioned or state-run sports gambling schemes.[5] From the outset, there was concern that PASPA was a federal intrusion on the rights of states to set their own gambling policy.[6] The Supreme Court would ultimately address these concerns in Murphy v. Nat’l Collegiate Athletic Ass’n.
Murphy v. Nat’l Collegiate Athletic Ass’n.
In 2012, the state of New Jersey passed a law permitting sports gambling. The National Collegiate Athletic Association (NCAA), along with several professional sports leagues, sued New Jersey Governor, Phillip Murphy, arguing that the law violated PASPA. New Jersey countered that PASPA itself violated the Constitution’s “anti-commandeering” principle, which prevents the federal government from commanding states to regulate or legislate in a specific way.[7] The case reached the Supreme Court in 2018, where PASPA was struck down as unconstitutional. The Court found that PASPA violated the Tenth Amendment because it dictated what state legislatures may or may not do.[8] The Court reasoned that it would undermine federalism if a state enacted or refrained from enacting a law solely because Congress commanded it to do so.[9]
Post-Murphy
The Murphy decision triggered a transformation in the sports betting landscape. Because PASPA was no longer valid, each state was left to regulate and legalize sports betting at its discretion. As a result, betting on college sports also became permissible throughout the nation, with many states having no restriction on college sports betting.[10] As wagering on college games has become more widespread, athletes have become the target of harassment by angry fans. A study conducted by the NCAA during the 2024 March Madness tournament reported over 540 abusive, betting-related messages.[11] The NCAA also reported that one in three high-profile athletes received abusive messages from people with betting interests.[12] Angry bettors have even gone so far as to request money from players on platforms such as Venmo to compensate for bets lost due to the students’ performance.[13]
In response to the harassment of college athletes, the NCAA announced a partnership with Venmo in August 2025 to support student-athletes who are the subjects of abuse from angry fans.[14] The partnership includes a hotline for athletes to report harassment and inappropriate requests. Venmo will also monitor social media and transaction trends that may trigger unwanted activity following sporting events.[15] Clint Hangebruak, the NCAA’s managing director of risk management, expressed hope that other social media platforms follow Venmo’s lead and implement their own protections for student athletes to help curb harassment.[16] He emphasized that these protections are necessary to ensure student- athletes can continue to use social media in the same manner as their peers without fear of harassment.[17]
Conclusion
The Supreme Court’s decision in Murphy reshaped the sports betting landscape by transferring the regulatory power from the federal government to the states. But in doing so, the decision inadvertently left student-athletes vulnerable to harassment from disgruntled fans and bettors. Due to the current lack of uniform regulation for betting on student-athletes, private entities such as Venmo and the NCAA have stepped in and established their own mechanisms for monitoring abuse.
The Murphy decision and the events that followed highlight how legal decisions can produce consequences that may not have been within the scope of immediate consideration. While Murphy started as a question about federal intrusion into state sovereignty, it has evolved into a debate over the protection of student-athletes. As sports betting continues to grow, the question of who bears the responsibility of protecting student-athletes remains. Is it the responsibility of the federal government or private actors?
Rachel Bender is a second-year law student at Cardozo School of Law and a staff editor at the Cardozo Arts & Entertainment Law Journal. Rachel is interested in entertainment and sports law. She is also a big fan of the Sacramento Kings.
_________________________________________________________________
[1] Karen Brown, As sports betting explodes, should states set more limits to stop gambling addiction?, NPR (Sept. 30, 2025, 5:00 AM), https://www.npr.org/sections/shots-health-news/2025/09/30/nx-s1-5553428/sports-books-betting-gambling-addiction-massachusetts-gamesense [https://perma.cc/7QHK-84HE].
[2] John Zenor, Auburn QB Thorne says angry bettors sent him Venmo requests after loss, AP News (Sept. 10, 2024, 5:25 PM), https://apnews.com/article/auburn-thorne-sports-betting-venmo-a213453b96aa3c9f4e9d45ec3f737ab2 [https://perma.cc/J966-7FHW].
[3] Id.
[4] Eric Meer, The Professional and Amateur Sports Protection Act (PASPA): A Bad Bet for the States, 2 UNLV Gaming L.J. 281, 293 (2011).
[5] Id. at 287.
[6] Id. at 288.
[7] Murphy v. Nat’l Collegiate Athletic Ass’n, 584 U.S. 453, 459 (2018).
[8] Id. at 471.
[9] Id.
[10] BCSGUESTWRITER, Which States Allow Bets on College Sports?, Business of College Sports (Apr. 16, 2025), https://businessofcollegesports.com/other/which-states-allow-bets-on-college-sports/ [https://perma.cc/8EHP-5KW7].
[11] NCAA calls on fans, social media platforms to curb abuse as it releases first online harassment study, NCAA (Oct. 10, 2024, 11:00 AM), https://www.ncaa.org/news/2024/10/10/media-center-ncaa-calls-on-fans-social-media-platforms-to-curb-abuse-as-it-releases-first-online-harassment-study.aspx [https://perma.cc/JC5E-DQ6C].
[12] Zenor, supra note 2.
[13] Id.
[14] NCAA partners with Venmo to assist athletes who face harassment on the payment app, AP News (Aug. 26, 2025, 11:46 AM), https://apnews.com/article/ncaa-venmo-college-athletes-9755af3e347e6e6cf64af2bc6472fde3 [https://perma.cc/N25G-8AST].
[15] David Purdum, NCAA, Venmo partner to combat harassment of college athletes, ESPN (Aug. 26, 2025, 7:56 AM), https://www.espn.com/college-sports/story/_/id/46077993/ncaa-venmo-partner-combat-harassment-college-athletes [https://perma.cc/3A6H-SPH8].
[16] Id.
[17] Id.
