By Emma Fernald, of Tulane Sports Law
On March 5, 2026, Judge Julie Rebecca Rubin denied a temporary restraining order in Brock Murtha’s suit challenging the NCAA’s denial of a Season-of-Competition Waiver. The court held that Murtha failed to meet the standard for extraordinary relief. Murtha v. Nat’l Collegiate Athletic Ass’n, No. 1:26-cv-00719-JRR (D. Md. Mar. 2, 2026).
Murtha, a senior infielder at the U.S. Naval Academy, sought a fifth year of NCAA eligibility after the association counted his six-game appearance total at Notre Dame during 2021 as a full season of competition. He argues that his limited participation should not have exhausted a year of eligibility and that losing this season would hinder his leadership development before commissioning as a Marine Corps officer. The dispute followed the NCAA’s denial of a waiver and its refusal to reconsider the decision after Navy missed the 30-day appeal deadline.
On February 20, 2026, Murtha sued the NCAA in the U.S. District Court for the District of Maryland for breach of contract and related claims, alleging the NCAA improperly refused to reopen his eligibility case. He sought damages and injunctive relief, including a temporary restraining order that would allow him to compete this season. The NCAA opposed the motion, arguing that Murtha failed to satisfy the requirements for injunctive relief.
Judge Rubin found that Murtha had not demonstrated entitlement to a temporary restraining order. She concluded that the evidence did not justify altering the status quo. Rubin emphasized that a TRO is “extraordinary relief” and cannot be used to accommodate a player’s request midseason. She further noted that Murtha would still need to obtain a mandatory injunction, which she described as “very difficult, if not impossible.” The court therefore denied the motion, leaving Murtha ineligible to compete this season.
“The harm I am facing is not the loss of fun or games,” Murtha wrote in a declaration attached to his complaint. “It is the loss of critical leadership reps that are essential to my ability to lead Marines in high-consequence environments.” Murtha is represented by Christine Brown of Christine Brown & Partners in Old Greenwich, Connecticut. The court’s denial of the temporary restraining order leaves Murtha unable to compete while the case proceeds.
