The preliminary injunction issued by the Circuit Court of DeKalb County, Alabama blocking enforcement of the NCAA’s six-year show-cause penalty against former University of Tennessee head football coach Jeremy Pruitt represents more than another legal challenge to college sports governance. The ruling rests on due process grounds that carry implications extending beyond this individual case, reaching directly into both the NCAA’s existing enforcement apparatus and the College Sports Commission’s emerging investigative framework.

The Investigation and Enforcement Action

Jeremy Pruitt’s lawsuit challenges an NCAA enforcement process he characterizes as structurally flawed and procedurally unfair. The case arose from recruiting violations allegedly occurring during his tenure at Tennessee, resulting in a six-year show-cause order that effectively bars him from coaching at NCAA institutions.

According to Pruitt’s complaint, the University of Tennessee conducted its own internal investigation, despite having institutional incentives to attribute violations to individuals rather than the university itself. The NCAA then relied substantially on that investigation while limiting Pruitt’s ability to mount a defense. He was not permitted to compel witnesses, cross-examine accusers, or obtain third-party discovery. Where witness testimony conflicted, the complaint alleges, credibility determinations consistently went against Pruitt even when reliability concerns existed.

The result was a sanction rendering Pruitt effectively unemployable in college football—imposed, he argues, through a process designed to reach a predetermined outcome rather than conduct genuine fact-finding.

The Court’s Preliminary Injunction Order

The court granted Pruitt’s motion for preliminary injunction, applying Alabama’s four-factor test and finding Pruitt satisfied each element for the following reasons:

1. Irreparable harm. The court found that coaching opportunities in college football are time-sensitive and market-dependent; lost seasons cannot be recovered, and professional reputation erodes in ways money damages cannot remedy. The court emphasized that coaching encompasses not just income but reputation, experience, and career trajectory.
2. No adequate legal remedy exists. The court also found that even if there were easily calculable damages, such monetary damages would not restore lost opportunities or professional standing during the years a show-cause order remains active.
3. Reasonable likelihood of success on the merits. This finding flowed from the court’s skepticism of the due process that the NCAA’s investigation afforded Pruitt. After reviewing the Public Infractions Decision, the court determined a jury could reasonably conclude Pruitt was denied a fair and impartial opportunity to defend himself.
4. The balance of hardships favored Pruitt. The court found that enjoining enforcement imposed minimal burden on the NCAA while continued enforcement would substantially harm Pruitt during litigation.

The Due Process Problem

The DeKalb County Circuit Court’s analysis reveals a fundamental concern with procedural fairness. The court’s reasoning returns repeatedly to deficiencies in how the investigation was conducted and how evidence was evaluated, including:

• selective credibility determinations that credited evolving witness statements when harmful to Pruitt but discounted them when helpful;
• absence of adversarial safeguards, including no meaningful ability to cross-examine witnesses or compel testimony;
• institutional imbalance, with the university—itself a subject of investigation—granted investigative access denied to Pruitt; and
• questions about whether the Committee on Infractions hearing served a truth-seeking function or merely ratified the university’s narrative.

The court invoked Alabama state caselaw precedent allowing judicial intervention when a voluntary association’s actions lack fairness or proper jurisdiction. While courts typically defer to internal governance processes, that deference disappears when enforcement becomes arbitrary or fundamentally unfair.

This is where the court’s ruling becomes consequential. The NCAA did not lose on a technicality or because of changing college sports rules. It lost because its process, as applied, failed to meet basic expectations of procedural justice that courts will enforce.

What This Means for the CSC’s Emerging Enforcement Powers

The timing makes this ruling particularly relevant. As readers of this blog know, the College Sports Commission has signaled its intent to expand investigative and enforcement authority through a new membership agreement framework, including enhanced cooperation obligations and sanctions powers. This model aims to centralize the NCAA’s enforcement capabilities.

But the Pruitt order offers a cautionary lesson: enforcement power without adequate due process invites judicial intervention.

The features the CSC appears positioned to expand—compelled implementation of CSC penalty determinations, limited adversarial procedures—are similar to the NCAA’s traditional enforcement procedures that troubled the Pruitt court.

The CSC’s legitimacy depends not on being more aggressive than the NCAA, but on being more procedurally sound. If the CSC’s enforcement apparatus does not address due process concerns raised by the Pruitt court, it may be susceptible to similar due process challenges.

The Path Forward

The Pruitt injunction is a clear signal. Courts are willing to look past the NCAA’s claims of “internal governance” and examine whether its enforcement systems operate with genuine fairness, neutrality, and procedural balance.

For the NCAA, Pruitt exposes the vulnerability of an enforcement framework built on investigative asymmetry and limited adversarial testing. For the CSC, the decision provides both warning and roadmap as it constructs its own enforcement mechanisms to address the rapidly evolving NIL landscape.

The question facing both the NCAA and CSC is whether they will learn from this ruling or repeat the mistakes it identifies.