Recent NCAA Eligibility Rulings Highlight Expanding Judicial Role in College Athletics Governance

In the era of name, image, and likeness (NIL), student-athletes are increasingly challenging eligibility limits, waivers, and participation rules, often seeking preliminary injunctions to preserve both competitive opportunities and significant NIL-related earnings. While the NCAA has prevailed in most cases, a growing number of courts—particularly at the state level—have granted temporary relief, creating variability in the application of eligibility rules.

Courts have been scrutinizing eligibility decisions under antitrust, contract, and good faith theories while applying traditional injunction standards that heavily weigh irreparable harm and economic impact.

The contrasting outcomes in the case of one SEC quarterback, Trinidad Chambliss, [1] who challenged the NCAA’s denial of a medical waiver and recently obtained a preliminary injunction permitting a sixth year of eligibility, and another SEC quarterback, Joey Aguilar, [2] who argued his time playing in junior college should not count and was denied relief seeking extended participation, illustrate the fact-specific and jurisdiction-dependent nature of these disputes.

This is particularly relevant for universities and their athletic departments, student-athletes, and businesses engaged in the business of collegiate sports as they raise questions about the enforceability of NCAA rules, contractual obligations, and the reach of state law.

KEY TAKEAWAYS

• Courts are increasingly willing to scrutinize NCAA eligibility restrictions under antitrust and related legal theories as well as contract law and the implied duty of good faith and fair dealing.
• Courts are asked to answer what individual circumstances, such as redshirt or junior college years, allow for extended NCAA eligibility.
• Judicial involvement is contributing to a hybrid governance model in which NCAA rules remain operative but are subject to case-by-case and potentially state-by-state interpretation and potential modification.
• Collegiate athletes are increasingly filing petitions in state courts, which have been awarding athletes relief at a higher rate than federal courts in NCAA eligibility cases.
• While frequently construed in concert with federal antitrust laws, state antitrust statutes can vary in terms of their breadth, potentially leading to inconsistent outcomes based on jurisdiction and governing law.
• Preliminary injunctions—though temporary—can materially affect competitive balance and roster planning.
• Continued litigation is likely to accelerate calls for legislative or structural reform to establish greater uniformity.

THE EVOLVING LEGAL FRAMING OF ELIGIBILITY

Historically, NCAA eligibility rules were viewed as internal governance mechanisms within a voluntary association. Courts often deferred to the NCAA’s regulatory authority absent clear procedural irregularities; however, recent challenges reflect a shift in how eligibility is characterized and litigated.

In the current NIL era, collegiate athletes are increasingly seeking to enjoin application of NCAA eligibility rules and/or eligibility decisions including by arguing that (1) the limitations violate antitrust statutes because they limit competition and/or (2) they violate an implied duty of good faith and fair dealing because the NCAA’s application of its rules is arbitrary and/or unreasonable. Such legal challenges pose various questions regarding the legality of established NCAA eligibility rules and its enforcement on a case-by-case basis.

In the preliminary injunction context, where nearly all of this litigation has arisen to date, courts are assessing:

• Likelihood of success on the merits
• Irreparable harm
• Balance of equities
• Public interest

Where relief has been granted, courts have in some instances credited arguments that the loss of a remaining season may constitute irreparable harm where NIL opportunities, draft prospects, and/or professional exposure are implicated. At the same time, the denial of similar relief in other cases demonstrates that outcomes remain highly fact-dependent. Courts are not applying a uniform standard that automatically favors extended eligibility—in fact, student-athlete eligibility challenges have failed in most cases.

CHAMBLISS AND AGUILAR: COURT ANALYSIS

In Chambliss v. NCAA, the Chancery Court of Lafayette County, Mississippi granted a preliminary injunction in favor of the student-athlete, allowing him to participate in intercollegiate football at Ole Miss during the 2026-2027 academic year. Chambliss argued that he was an intended third-party beneficiary of the contract between the NCAA and its member institutions and that the NCAA had failed to honor the implied duty of good faith and fair dealing by unreasonably denying his eligibility waiver request.

The dispute centered on whether the NCAA’s denial of a waiver of its five-year period of eligibility was consistent with its own bylaws and whether the substantial medical documentation provided, including expert opinions, was sufficient to demonstrate a medically valid hardship.

The Mississippi court sided with Chambliss, enjoining the NCAA from prohibiting his participation pending final resolution. The court concluded that Chambliss satisfied the criteria for an eligibility extension under NCAA Division I Bylaw 12.6.1.7.1 and the NCAA’s actions (particularly its reliance on “semantics” regarding the term “contemporaneous” medical documentation) were inconsistent with its own bylaws, which allow for both “contemporaneous and non-contemporaneous medical documentation” to such hardship waivers, and unreasonable given Chambliss’s medical record/history.

Completing the preliminary injunction analysis, the court held that denying Chambliss’s participation constituted irreparable harm due to the unique economic and developmental opportunities associated with collegiate athletics and NIL rights; the balance of harms favored Chambliss; and the injunction was deemed in the public interest, promoting participation and competition.

In contrast, the Chancery Court for Knox County, Tennessee denied injunctive relief to the plaintiff in Aguilar v. NCAA, dissolving a prior temporary restraining order and allowing NCAA eligibility rules to remain in effect. Aguilar, a quarterback for the University of Tennessee, challenged the so-called “JUCO” rule under the Tennessee Trade Practices Act (TTPA) and Tennessee’s NIL statute. In support of his request, Aguilar provided an expert opinion that if he was permitted to return to the University of Tennessee as its starting quarterback his NIL value would be between $2 and $4 million.

The court applied Tennessee’s four-factor test for injunctive relief, finding that while Aguilar faced a threat of irreparable harm due to lost NIL opportunities (as in Chambliss), the balance of harms was neutral and the probability of success on the merits was lacking. Central to the court’s decision was Aguilar’s failure to demonstrate that the NCAA rule had a “substantial effect” on Tennessee trade or commerce, a requirement under controlling Tennessee state antitrust law, which the court observed has one of the broadest prohibitions on anticompetitive conduct of any state antitrust statute in the country.

The court also addressed constitutional issues under the dormant Commerce Clause, holding that applying the TTPA to regulate NCAA nationwide rules would impose an impermissible burden on interstate commerce. The court emphasized that the NIL statutes cited by Aguilar do not create a private right of action and are reserved for enforcement by the Tennessee Attorney General.

Even under a “rule of reason” analysis (i.e., the analysis performed when evaluating a federal antitrust claim), the court found insufficient evidence of substantial anticompetitive effects. As a result, the temporary restraining order was dissolved and the emergency motion denied, with the case set for trial on the merits.

EXPANDING JUDICIAL INFLUENCE IN COLLEGE SPORTS GOVERNANCE

Since November 2024, there have been more than 50 NCAA eligibility cases filed throughout the country, in both state and federal courts. Overall, the NCAA has succeeded in a majority of these cases, but plaintiff collegiate athletes have been more successful when filing in state court as opposed to federal court.

Absent congressional action or comprehensive reform, eligibility rules will likely remain subject to continued judicial scrutiny. Several potential developments bear monitoring:

• Further clarification on the standard for irreparable harm in eligibility cases
• Divergence among courts that could prompt appellate review on both the federal and state levels
• Inconsistent outcomes driven by differences in state antitrust statutes and the breadth of their prohibitions
• Renewed legislation on a state-by-state basis to limit the enforceability of NCAA eligibility limits
• Increased policy revisions by the NCAA in response to litigation and legislative trends

The broader trajectory suggests a continued shift from purely regulatory governance toward a framework in which student-athlete eligibility is evaluated through principles of economic opportunity and competitive fairness.

These eligibility disputes are part of a broader trend of judicial engagement in college athletics governance following the US Supreme Court’s decision in NCAA v. Alston. Litigation has increasingly addressed:

• Compensation restrictions
• Transfer constraints
• NIL-related policies
• Employment status
• Eligibility limitations

As a result, governance now operates in a hybrid environment wherein the NCAA’s rules, as amended to comply with the recent historic House Settlement, remain formally in place but their application may be altered through emergency judicial relief. This dynamic introduces variability across jurisdictions and competitive environments.

IMPLICATIONS FOR INSTITUTIONS

The recent wave of eligibility-related litigation carries significant implications for both institutions and student-athletes. From an institutional perspective, short-notice eligibility extensions granted through court intervention can materially disrupt roster and scholarship planning.

Athletics departments structure scholarship allocation models, recruiting cycles, transfer portal strategy, and long-term roster projections months—if not years—in advance. When a court grants midcycle eligibility relief, institutions may be required to recalibrate these projections on compressed timelines. As a result, colleges and universities may need to develop contingency frameworks to address unexpected eligibility changes that arise during an academic or competitive year.

There is also litigation risk and related strategic considerations: even where institutions are not named defendants, they may nonetheless face meaningful litigation-related consequences. Court challenges to NCAA determinations can raise immediate compliance and implementation questions, including whether and how to integrate an athlete who has received temporary relief.

Institutions may also be confronted with strategic decisions regarding whether to support or oppose requested relief, particularly in cases that could affect conference dynamics or future precedent. Pending court rulings can create operational uncertainty, underscoring the growing importance of coordination among athletics leadership, compliance personnel, and institutional legal counsel when eligibility disputes arise.

Competitive balance concerns further complicate the landscape. If courts continue to grant eligibility relief on an inconsistent basis, disparities may develop among conferences and individual programs. Uneven application of participation limits (especially in revenue-generating sports such as football and men’s and women’s basketball) could raise questions regarding competitive equity and the uniform enforcement of NCAA rules.

IMPLICATIONS FOR STUDENT-ATHLETES

For student-athletes, the evolving legal environment reflects a heightened willingness to challenge NCAA eligibility determinations, particularly in light of the economic realities of the NIL era. Courts are increasingly asked to consider the financial consequences of lost eligibility, including the potential loss of substantial NIL opportunities.

Consequently, preliminary injunctions have emerged as a strategic tool for preserving participation rights (and by extension related earning potential) while litigation proceeds. At the same time, inconsistent judicial outcomes create uncertainty regarding both the viability and timing of such challenges, leaving athletes to carefully weigh the risks and benefits of pursuing legal relief.

LOOKING AHEAD

Recent eligibility rulings do not establish a definitive doctrinal shift, but they do reinforce that NCAA eligibility and participation rules are no longer insulated from meaningful judicial review. Institutions should anticipate continued legal challenges, prepare for operational variability, and monitor developments as courts and the individual states further shape the contours of athlete compensation, eligibility, and mobility in the vacuum left by current congressional inactivity.

If you would like to discuss the implications of these developments for your institution or conference, please contact any of the authors of this LawFlash or your regular Morgan Lewis contact. For more information on developments in US college sports, visit our webpage.