I can't think of one school that doesn't do this for most smaller sports and road games for basketball occasionally. They're not bound to the same ethical commitments we are, nor should they be. They don't serve the same function.
At one school I covered, another reporter and I would joke that they only had one horizontal volleyball photo available because every time they made volleyball the main image on the site, it was the same photo. For at least two seasons.
I've never been at a newspaper that would use file art for a live game story. That includes my high school and college papers. But the goal of an public relations department is not the same as the goal of a newspaper.