Michigan and the NCAA are in for a long, bruising fight over allegations related to the Connor Stalions-led advanced scouting and sign-stealing scheme.

In its response to the association sent earlier this month, the university refutes many of the alleged rules violations and accuses the NCAA of “grossly overreaching” and “wildly overcharging” the program without credible evidence that other staff members knew of Stalions’ illegal in-person scouting system.

In the 137-page document — a portion of which Yahoo Sports obtained — Michigan makes clear that it will not enter into a negotiated resolution with the NCAA over the alleged wrongdoing, vigorously defending its former head coach, current head coach, several staff members and even Stalions, the low-level assistant who orchestrated one of the most elaborate sign-stealing systems in college football history on the way to the school winning the 2023 national championship. The school purports that the sign-stealing system offered “minimal relevance to competition,” was not credibly proven by NCAA investigators and should be treated as a minor violation.

An NCAA spokesperson confirmed that the association received Michigan’s response, but declined to provide additional details and refused to confirm the document that Yahoo Sports obtained. A Michigan spokesperson declined comment when reached, citing the ongoing nature of the investigation. A Big Ten official declined comment as well.

In its response, Michigan believes that the notice of allegations, sent to the school in August, makes “numerous factually unsupported infractions, exaggerates aggravating factors and ignores mitigating facts,” the document says. The school requests that the NCAA apply “common sense and commitment to fairness” and treat the case not as a serious Level I infractions case but a “Level II standard case.”

The document details why many of the 11 allegations against the school — six of them deemed as Level I — are without “merit or credible evidence,” the school contends, and that includes allegations against ex-head coach Jim Harbaugh and current head coach Sherrone Moore, who was an assistant on staff during Stalions’ advanced scouting operation and was found to have deleted text messages with him.

However, perhaps most notable in the document is an answer to a long-discussed question: Who originally tipped off the NCAA to Stalions’ scheme?

According to the document, the tipster derived from Michigan’s own campus. The unnamed source, which the NCAA has not disclosed, appears to have worked at the school, at least at one point. Michigan believes the confidential leaker was used by the NCAA to produce at least some of the charges in the notice of allegations, something in which it expresses “concern.”

While the school respects the secrecy of confidential sources, it says in the document, the NCAA can present evidence and infractions based only on “information that can be attributed to individuals who are willing to be identified.”

The case is now bound for a hearing before the Division I Committee on Infractions, an independent administrative body charged with deciding infractions cases. The committee has authority to set and conduct hearings as well as prescribe penalties.

However, Michigan is requesting a “pre-hearing conference” to discuss the origins of the tipster and their role in the charges against the school.

A hearing before the Committee on Infractions is likely to happen over the coming weeks as the school and association enter what could be a lengthy fight similar to the one that Tennessee waged against the NCAA in 2023 over recruiting violations. Eventually, the Volunteers avoided the dreaded postseason ban, instead suffering financial penalties and recruiting and scholarship reductions.

The NCAA’s notice of allegations, as well as Michigan’s response, did not stipulate proposed penalties against the school. However, six of the 11 violations are deemed to be Level I and the NCAA asserts that Michigan “failed to monitor” its football program given the severe nature and multi-year length of the Stalions scheme. The university and several of its coaches are considered repeat offenders, an allegation the school refutes in its response.

Two years ago, a separate investigation found both Harbaugh and Moore guilty of COVID-era recruiting violations. In that case, Michigan was placed on three years probation, and Harbaugh received a four-year show-cause order that effectively prevents him from coaching in college.

In its response, the school acknowledges that some impermissible in-person scouting appears to have occurred — “though less than the (NCAA) claims” — and that some recruiting violations occurred, as well. All of the wrongdoing, it says, will be addressed in the Committee on Infractions hearing and it will advise committee members of self-imposed penalties.

Michigan believes the COI will see that actual evidence has “not borne out” the NCAA’s initial assessment of “the resulting, sensational public narrative, or the approach taken in the notice of allegations,” the response says.

Despite producing phone, computer and other data to the NCAA, investigators have not proven that “any coaches were aware of, much less participated in” the scheme, Michigan says.

Sherrone Moore’s deleted texts

Of the NCAA’s 11 allegations against the school — six of them related to Stalions and his scheme — one of them stands as the most serious and impactful for the current state of the program: Moore, then an assistant, deleted 52 text messages with Stalions on the very day (Oct. 19, 2023) that Yahoo Sports broke the story of the NCAA’s investigation into the school.

In its response, Michigan and Moore acknowledge the deleted messages. However, the school contends that the texts were “innocuous and not material to the investigation” and that Moore cooperated fully with the investigation, even turning over his phone for imaging — a move that revealed the previously deleted messages.

The coach told school officials that he deleted the messages in anger and frustration shortly after the bombshell news story broke, suggesting that he did not want one person, Stalions, to receive credit for “all the work that” coaches and players put into the championship run.

“So, [I] deleted all the information — all Connor, on my personal phone,” he said in Michigan’s response. “And it wasn’t to hide anything, it was just that — I was just extremely angry of, you know, the type of person that would do that to this program and these kids.”

In its response, Michigan highlights several of the text messages between the coach and Stalions. While many of them are innocuous — Stalions reminding Moore of a prospect’s birthday, for instance — several of the messages were related to sign stealing.

However, the university notes, none of the texts were specifically about the in-person advanced scouting system, where Stalions allegedly organized himself and a group of low-level staff, friends and family members to record, in person, as many as 52 games of Michigan’s upcoming opponents over a three-year stretch.

While NCAA rules prohibit in-person scouting of future opponents, the association permits scouting opponents’ signs during games against that opponent, from television broadcast or taped recordings.

Some of the text messages between Moore and Stalions paint a fascinating picture of the behind-the-scenes nature of Michigan’s sign-stealing effort — one that, according to the school, is perfectly within the rules and is a fairly normal art among college football staffs.

– In an August 2022 text from Stalions to Moore, Stalions describes needing time to meet with the coach to discuss “a juicy report for you on CSU,” as in Colorado State, which Michigan opened the season against that year. The Wolverines won, 51-7.

– In October of 2022, Stalions sent Moore a single text about Michigan State’s blitzing signals, rules and tendencies. “Michigan played Michigan State every year and Michigan State never changed its signals,” the document says in providing context with the text.

– In a November 2022 text, Stalions suggests to Moore that Michigan should change its signals ahead of the Ohio State game. Moore responded that he’ll “think about it.” And Stalions responds that, “Nebraska is screwed,” a reference to the fact he could easily decipher the Huskers’ signals ahead of the Wolverines’ game against them that very week. Michigan won that game, 34-3. But Moore told university officials that Nebraska used wristbands, so there were no signals to steal.

– Perhaps the most interesting text came in April 2023. Stalions sent a note to Moore that Central Michigan assistant coach Jake Kostner planned to visit the facility to meet with Moore. Central Michigan opened the 2023 season with Michigan State, which UM regularly played. Ironically enough, Stalions is believed to have attended that game — CMU vs. Michigan State — while in disguise. In fact, CMU fired Kostner last fall as the NCAA investigated the matter of Stalions’ alleged appearance on the sideline of the game.

Connor Stalions’ scheme

The NCAA accuses Stalions of engaging in in-person scouting of 52 games over the 2021, 2022 and 2023 seasons, many of them involving scheduled opponents of Michigan.

In its response, the university contends that Stalions attended just one of those games and that only eight more were attended by a then-Michigan staff member — lower-level managers that Stalions assigned to attend and presumably record sideline footage for his signal system.

Other games were attended by Stalions’ friends or family and do not violate NCAA bylaws, the school contends. Michigan also asserts that “in many instances” the only evidence of the in-person scouting system is that “Stalions purchased a game ticket.”

Michigan also argues that many of the in-person scouting allegations “do not support the six elements of a completed indirect scouting violation,” including lack of witness statements or eyewitness evidence that videos were taken from the stands at many of the games in which Stalions purchased tickets. However, in the NCAA’s notice of allegations, the association did attach some videos and photos of people near the seats Stalions purchased recording the sideline.

In one interesting bit, a handwritten note was found on Stalions’ desk and was included as a reference to the plan for the Ohio State game in 2023 that states, among other things, “Focusing on them all year + watching every TV copy, sky cam.” The university contends that this supports that much of Stalions’ sign-stealing system came through legal avenues and not in-person scouting.

“An enormous amount of signal decoding was therefore permissibly done with TV and other publicly available footage,” the response says.

In another interesting note, Michigan reveals that Stalions traded opponents’ signal plans with other schools and received signal plans for opponents from others as well, including getting plans from Rutgers and Nebraska staff members for the signals of Michigan State and UNLV. These were listed in documents as “potential alliances.”

Michigan also claims that players and staff members only used Stalions’ signal boards on a limited basis and that they did not provide a competitive impact. Michigan players used pre-snap calls of “birds” (a pass) and “rabbits” (a run) even before Stalions joined the staff, the school says. They often determined such, not by signals, but by offensive line stance, the offensive formation or other tells.

Michigan refutes the NCAA’s assertion that it “failed to monitor” its football program in light of the Stalions scheme after “at least two members of the football program raised concerns about Stalions’ process for deciphering opponents’ signals,” according to the NCAA. “The information was not reported to compliance for further review and/or willfully ignored so as to not learn about the potential violations.”

One of those members was then-running backs coach Mike Hart, who told NCAA investigators he received a call in September 2023 from a Rutgers staff member who told him that Michigan was stealing signals and “going further” than most do. Hart brought attention to this call to then-defensive coordinator Jesse Minter. The Rutgers staff member mentioned Stalions specifically.

Michael Neyman, a low-level Michigan staff member, raised concerns about Stalions’ sign-stealing system and refused to be a part of it when Stalions wanted him to rent a car to scout a football game at Georgia — a team Michigan could have eventually played in the playoff but a team not on the program’s schedule, making it permissible to scout them, according to UM’s response.

Neyman approached assistant coach Chris Partridge to inform him that he did not want to be part of Stalions’ scheme. Partridge went to Stalions directly and said he told him, “You’re not using this kid in your signal organization stupid thing, so, like, just have him be a manager.”

Jim Harbaugh, other former coaches

Some of the NCAA’s 11 allegations are unrelated to Stalions’ scheme and are instead connected to recruiting violations allegedly committed by assistant coaches, many of them no longer with the program.

For instance, Michigan acknowledges that former assistants Partridge and Minter sent more than 100 combined texts to a recruit outside of the NCAA’s contact period, but the school refutes the allegation that several former assistants held tryouts in the spring of 2023 with recruits.

As for Harbaugh, the school says the NCAA’s allegation against him is “without merit.” The NCAA alleges that Harbaugh failed to cooperate between Oct. 20 and Jan. 24, 2024 when he did not produce text and telephone records from his personal cell prior to his departure from the school.

Imaging of Harbaugh’s phones — his personal and work — were part of a large initial collection of data that included imaging of phones and other devices from 10 individuals, the school says, including two computers assigned to Stalions and an external hard drive owned by Stalions.

However, there were “legitimate concerns” that the data being imaged contained personal and sensitive information and/or attorney-client communications, so images were withheld. The NCAA did not receive Harbaugh’s images by the deadline and deemed him to have failed to comply.

Michigan also refutes three of the NCAA’s four allegations that Stalions impeded the investigation, including that Stalions failed to preserve all pertinent information by (1) declining to produce his personal phone for imaging, (2) withholding and removing hard drives from his office, (3) putting relevant information into a backpack and instructing a staff member to take it to an unpaid student intern’s house where he (Stalions) could pick it up, and (4) instructing a student intern to delete potentially relevant information.

The fourth allegation, the school says, is the only one substantiated.

Michigan believes that the NCAA’s allegation against Partridge — who it fired — is unsubstantiated. The association says he violated a bylaw by pressuring an athlete to “protect” the football coaching staff by providing false or misleading information when answering questions. “Partridge was terminated by the institution for disregarding the institution’s directive to not discuss the investigation with anyone,” Michigan said. “His failure to abide by the institution’s directive does not constitute a violation of any NCAA bylaw.”