With fall sports in full swing, it may be easy to miss the fact that the NCAA has also been busy competing in the courtroom. On the same day that a federal judge in California preliminarily approved a $2.78 billion settlement permitting college athletes to apply for payment for their on-field efforts, the U.S. District Court for the Middle District of North Carolina denied a UNC tennis player’s motion to enjoin the NCAA from enforcing prize money forfeiture rules during the pendency of her antitrust case against the organization.
What You Need to Know:
- A UNC tennis player has filed a class action lawsuit asserting that NCAA rules restricting the amount of prize money individual athletes can accept without forfeiting their eligibility violates antitrust laws.
- While the court has not yet ruled on the merits of the case, the U.S. District Court for the Middle District of North Carolina denied the plaintiff’s request to enjoin the enforcement of the NCAA’s prize money rules during the pendency of the suit.
- The court found insufficient evidence to satisfy the standard required for a mandatory injunction, but did note that the NCAA’s argument that its prize money rules are a “non-commercial eligibility requirement” was “unlikely to be successful.”
Tar Heel tennis player Reese Brantmeier filed a putative class action lawsuit earlier this year on behalf of herself and other students participating in Division I individual sports, including tennis, golf, swimming, and track and field, among others. The antitrust suit alleges that, as a function of amateurism rules prohibiting the amount of prize money students can accept, the NCAA is effectively engaging in price-fixing that artificially reduces earning opportunities for athletes in individual sports. In Brantmeier’s case, despite earning nearly $50,000 while competing in the 2021 U.S. Open at age 16, NCAA regulations only permitted her to accept $10,000 per calendar year in order to maintain her future college eligibility.
While Brantmeier’s underlying suit continues, her effort to bar the NCAA from enforcing its prize money limits during the pendency of her antitrust case was denied on October 7, 2024. After engaging in a thorough analysis of the antitrust factors at play, M.D.N.C. Chief District Judge Catherine Eagles ultimately ruled that Brantmeier had not made a clear showing that she was likely to succeed on the merits. In particular, Judge Eagles found that, at this stage, there was insufficient evidence to “conduct a fact-specific assessment of market power and structure in each of the alleged markets of individual sports” and then to “determine whether the challenged rules cause anticompetitive effects,” particularly since Brantmeier was seeking a mandatory injunction.
The court also noted that because there are “many differences in how [the identified sports] operate at the college and professional levels, with varying opportunities for professional competition,” those points of divergence “underscore the need for the kind of assessment of each market that is not yet possible on this record.” However, the denial of the injunction does not doom the suit, and Judge Eagles did note that the NCAA’s contention that its prize money rules are a “non-commercial eligibility requirement” not subject to the Sherman Act’s antitrust prohibitions was “unlikely to be successful.”
In the end, this suit will continue to be one to watch for colleges and universities with programs that may be impacted by prize money and amateurism rules.
