By Bridget Rachek, of Tulane Sports Law
On November 5, 2025, U.S. District Judge Rebecca Goodgame Ebinger dismissed the federal lawsuit of Iowa College Athletes versus the Iowa Department of Public Safety’s Division of Criminal Investigation (DCI). Judge Ebinger held that although the investigators’ warrantless geolocation search was unconstitutional under the Fourth Amendment, the defendants were entitled to qualified immunity because the right at issue was not clearly established at the time of the investigation.
The investigation began in 2021, after concerns arose that college athletes were violating NCAA sports-wagering bylaws. By 2023, several athletes faced criminal charges for underage gambling or falsifying records related to online wagering. Some athletes were permanently stripped of their collegiate eligibility through NCAA discipline. During the investigation, DCI reportedly used geolocation software from sportsbook apps such as FanDuel and DraftKings, which allowed agents to track athletes’ locations inside athletic facilities without obtaining a warrant. In April 2024, current and former athletes from the University of Iowa, Iowa State University, and Ellsworth Community College filed suit in the U.S. District Court for the Southern District of Iowa, naming the DCI and several agents as defendants. The plaintiffs allege that officers accessed their historical app-generated location data in a manner that constituted an unreasonable search under the Fourth Amendment, and the search warrants later obtained for their phones were invalid because they were based on evidence collected without a warrant. The DCI agents denied wrongdoing, arguing that their actions were lawful within the scope of a felony match-fixing and gambling investigation and that, at minimum, qualified immunity protected them from liability, since no clearly established legal precedent prohibited the use of geolocation verification systems in this context.
In her opinion, Judge Ebinger acknowledged that the athletes had “sufficiently alleged” a Fourth Amendment violation but ultimately held that the DCI agents were shielded by qualified immunity. She explained that although warrantless collection of historical geolocation data “would be unconstitutional under traditional Fourth Amendment principles,” courts had not yet determined whether information from sportsbook verification systems constituted a search requiring a warrant. Because the law governing app-generated geolocation data “was not clearly established at the time of the investigation,” the DCI agents could not be held personally liable. Judge Ebinger also ruled that the subpoenas used to obtain athlete information served a lawful purpose under Iowa’s felony match-fixing statute. As a result of these findings, her ruling dismissed the lawsuit in full and ended proceedings at the district-court level.
“The Court found that the Defendants violated our clients’ rights; however, dismissed the case due to the judicially created doctrine of qualified immunity,” plaintiffs’ attorney James Roberts said in a statement. He criticized the “clearly established” standard, stating: “The government should not get off on a technicality — simply because there isn’t a case telling them they can’t use this technology to violate people’s rights. We will be appealing this ruling to the United States Court of Appeals for the Eighth Circuit and are prepared to take this case to the Supreme Court of the United States.” The Iowa Attorney General’s Office declined to comment on the dismissal. The case has been dismissed, with appeal proceedings expected.
Source(s)
- https://www.espn.com/college-sports/story/_/id/46871376/federal-lawsuit-brought-iowa-college-athletes-dismissed
- https://cbs2iowa.com/news/local/judge-dismisses-lawsuit-from-iowa-athletes-over-sports-betting-investigation
- https://www.1630kcjj.com/2025/11/07/judge-dismisses-lawsuit-between-iowa-student-athletes-and-gambling-probe-investigators/
