Trinidad Chambliss’ lawsuit in the Chancery Court of Lafayette County, Mississippi, asks the court to bar the NCAA from enforcing its eligibility denial and to require the association to apply its bylaws as written and as promised.
NCAA Bylaws
The Five-Year Rule Under Fire — Again: Ortega v. NCAA and the Latest Antitrust Challenge to Eligibility Limits
The NCAA’s five-year eligibility rule continues to face sustained antitrust scrutiny. The most recent challenge has been raised in the Southern District of Iowa by Cuban-born Division I wrestler Reineri Andreu Ortega in the case Ortega v. NCAA, No. 25-CV-00496. As with similar challenges, Ortega challenges the NCAA’s practice of starting an athlete’s eligibility clock before the athlete ever enrolls at an NCAA institution, arguing that the rule unlawfully restrains athlete labor markets in violation of Section 1 of the Sherman Act.
Utah Starts the Private Equity NIL Race
By Michael S. Lowe & George Pla on
On December 9, 2025, the University of Utah, in what appears to be the first such deal of its kind, announced plans to partner with Otro Capital in a private equity arrangement. The deal is projected to generate approximately $500 million in capital for the university’s athletic programs.[i] Otro Capital is a New York-based firm that invests in sports teams and leagues.[ii]
Sixth Circuit Dismisses NCAA Appeal as Moot: Pavia’s College Athlete Eligibility Continue
By Michael S. Lowe & Philip Nickerson on
Posted in Student Athlete Eligibility
Background: From the Trial Court to the Appeal
Diego Pavia’s journey to a NCAA Division I starting quarterback position was anything but conventional. After leading his junior college (JUCO) team to a national championship, Pavia transferred to first one, then a second, Division I school. By 2024, Pavia became a breakout star in the SEC, leading his school to a historic win and drawing attention from NFL scouts. He also began receiving lucrative offers tied to his name, image, and likeness, yet his eligibility was in doubt.
Martinson v. NCAA: NCAA’s Five-Year Eligibility Rule Is Commercial and Subject to the Sherman Act
By Michael S. Lowe & Philip Nickerson on
Posted in NCAA Bylaws, Student Athlete Eligibility
Former University of Nevada, Las Vegas (UNLV) football player Tatuo Martinson is the latest NCAA athlete to successfully convince a federal district court to enjoin the NCAA from enforcing its “five-year eligibility rule” against a former junior college (JUCO) athlete. Martinson joins Diego Pavia,[1] Jett Elad,[2] Cortez Braham Jr.,[3] and four West Virginia University football players[4] as having prevailed on this issue, in contrast to James Coley Jr.,[5] Jagger Giles,[6] and Jackson Hasz,[7] who had similar efforts rebuffed by the NCAA.
Moving the Goalposts: CSC Adds and Subtracts Guidance on the “Valid Business Purpose” Standard
By Callan G. Stein & Brett Broczkowski on
As we reported last week, the College Sports Commission (CSC) issued initial guidance on how it would evaluate student-athlete NIL deals. As part of that guidance, the CSC promised to make available additional information “pending discussions with House class counsel.”
Seventh Circuit Overturns Fourqurean Fifth-Year Preliminary Injunction
On July 16, the U.S. Court of Appeals for the Seventh Circuit, in a 2-1 decision, overturned a preliminary injunction that would have granted University of Wisconsin cornerback Nyzier Fourqurean a fifth year of eligibility. The NCAA’s “Five-Year Rule” limits student-athletes to four seasons of competition within a five-year period. Fourqurean played four seasons: two at Grand Valley State University and two at the University of Wisconsin. The University of Wisconsin requested a waiver of the Five-Year Rule from the NCAA, citing circumstances that reduced Fourqurean’s playing time in his first season.
CSC Publishes New Guidance for NIL Deal Review
By Callan G. Stein & Brett Broczkowski on
Posted in NCAA Bylaws
On July 10, the College Sports Commission (CSC) published guidance on its website setting out additional information concerning the criteria for evaluating student-athlete NIL deals.
Newly Formed College Sports Commission Appoints CEO and Head of Operations and Deputy General Counsel
Posted in NCAA Bylaws
The newly formed College Sports Commission has named its first two executive leaders as it begins formal operations in the wake of the House v. NCAA settlement. Bryan Seeley[1] will serve as the commission’s inaugural chief executive officer and Jonathan Bramlette[2] will serve as its director of operations…
“NIL Go”: Deloitte Establishes Basic Framework to Review Third-Party NIL Deals
A three-page memo distributed to schools provides further clarity regarding Deloitte’s role as the approved clearinghouse for name, image, and likeness (NIL) deals, as outlined in the House settlement and guidance documents. Deloitte’s NIL clearinghouse and review platform will be known as “NIL Go.” We briefly addressed the role of the NIL clearinghouse in a previous blog post.