Yes, and it happened back in the dark ages in the mid 70s at my little Iowa high school (360 kids, grades 10-12).
Academic-challenged Jocks got away with easy-tract classes, others doing their homework, taking gym, study hall, art, english, then going out on work study through DECA for the rest of the day until practice. GPA was never ever taken into consideration regarding eligibility.
And as it turns out, for example, we graduated a 3-time state place winner wrestler who had to have his father help him with his janitorial application as the 'graduate' could barely read and write. Our administration at the time, who knew full well what was going on, looked the other way as long as the trophies kept piling up. Sad.