Former TCU wide receiver Kolby Listenbee filed suit in Dallas County state district court against TCU head coach Gary Patterson, the university and the Big 12 Conference, professing a pattern of abuse and harassment. The university responded with a filing for declaratory relief.

The receiver was injured during a touchdown reception against SMU during his senior season in 2015. The lawsuit, which was filed Jan. 3, 2018, alleges that Patterson, former offensive coordinator Doug Meacham, and other coaches “continually harassed, humiliated, pressured and threatened” Listenbee in an effort to “force Listenbee to return to play quickly.”

TCU released a statement on the lawsuit: “TCU takes tremendous pride in its long-standing tradition of excellence in providing a positive experience for its student-athletes, especially in the areas of care, prevention and rehabilitation of athletic injuries.”

Senior Associate Athletics Director for Student Services Gretchen Bouton, who is serving as a liaison for the counsel representing TCU, discussed the possibility of settling the case out of court.

“If we had any hesitation that we were in the wrong, this wouldn’t happen, and I definitely think we definitely stand by everything that has been said,” Bouton said.

According to the lawsuit, after Listenbee injured the cartilage that holds the pelvic bones together, he was pressured to return to the field before he fully recovered. He said in the suit that pelvic instability “requires a minimum of six months of rest and rehabilitation.”

Listenbee said in the lawsuit that TCU’s training staff “routinely injected him with pain and steroidal medications to make it possible for him to endure the pain of the injury while playing.”

Listenbee believes the “injection of steroids and pain medication, lack of rest due to harassment and abuse from the coaching staff, and strenuous play of football caused” damage to his pelvic cartilage to the point where a metal plate had to be inserted to fuse the bones. The lawsuit claims this ended Listenbee’s chances at the “NFL career he would have had.”

The lawsuit accused the Big 12 of failing to review TCU’s compliance with NCAA rules and policies. Specific defendants include head coach Gary Patterson, former athletic director Chris Del Conte, and former offensive coordinator Doug Meacham.

Listenbee missed two games in 2015, a season in which 25 players missed some time with an injury. The Horned Frogs finished 11-2 and ranked No. 7 after a triple-overtime victory over Oregon in the Alamo Bowl.

Despite the injury, Listenbee turned in a solid campaign, being named all-Big 12 honorable mention. He finished with 30 catches for 597 yards and five touchdowns. In the spring, he competed for TCU’s track team in the NCAA 100-meter championship.

Listenbee could not be reached for comment.

The Listenbee lawsuit isn’t the first time concerns have been raised about TCU football’s management of player safety. In 2010, the team physician, at the time Samuel Haraldson, told American Medical News that he was “verbally accosted” by Patterson after he did not allow running back Ed Wesley to re-enter a game against SMU after he suffered a head injury that Haraldson diagnosed as a concussion.

The game was televised by ESPN and the exchange between Patterson and Haraldson was shown live.

The following week Patterson was asked about Wesley’s availability for the coming game.

“He’s fine, and as far as I’m concerned he was fine 10 minutes after he got hurt,” Patterson said. “But, it was good that we protected him.”

Haraldson later issued a statement dismissing the blowup.

TCU’s filing didn’t request monetary relief outside of a reimbursement for court costs and legal fees. The university declares that the doctors were contractors under a Health Services Contract, so TCU maintains Listenbee’s filing should be against the actual healthcare providers, Dr. Michele Kirk and Jason Mogonye.

TCU is also trying to change the courthouse setting from Dallas County to Tarrant County where the school is located. The filing alleges that the former wide receiver’s address is a part of Tarrant County.

The Buffalo Bills drafted Listenbee in the sixth round of the 2016 NFL draft, but he was let go a year later without playing in a game. He spent time on the practice squad of the Miami Dolphins and Indianapolis Colts at the end of the 2017 season. The Colts signed him to a non-guaranteed reserve/futures contract Jan. 1.

“If there is anything possible that we did wrong, then I think this would be over right now,” Bouton said. “But I think we’re pretty confident that Gary’s record speaks for itself and our treatment of our student-athletes speaks for itself, so we’ll see how that goes.”