By Joseph Michael Ricco IV
Former University of Tennessee football quarterback Nico Iamaleava, once one of the highest-rated high school recruits in the country, entered the transfer portal and left for UCLA in mid-April, just months after leading the Volunteers to their first College Football Playoff appearance. His decision came after reported frustration over his NIL deal and growing tension between his camp and Tennessee’s coaching staff and collective. The situation has sparked new questions about how NIL contracts are being handled and whether schools have any real power to hold athletes to these agreements. This article breaks down what led to Iamaleava’s departure, examines the legal uncertainty around NIL contracts, shares perspective from sports law expert Professor Jodi Balsam, and looks at whether schools like Tennessee could take legal action as the House v. NCAA settlement continues to hang over the sport.
Why Nico Walked Away
Nico Iamaleava’s exit from Tennessee did not come out of nowhere. Reports of frustration between his camp and the university’s NIL collective, Spyre Sports Group, had been circulating for months leading up to his decision. Sources close to the situation said Iamaleava’s representatives, including his father, reached out to the collective in late December asking to renegotiate the terms of his NIL deal, aiming for a figure closer to the reported $4 million that other high-profile transfer quarterbacks like Carson Beck and Darian Mensah eventually secured. Iamaleava was reportedly set to make around $2.4 million at Tennessee. While his side has publicly denied pushing for that specific amount, the relationship between the quarterback and the program continued to deteriorate as the offseason unfolded.
The situation reached a breaking point in April when Iamaleava skipped practice ahead of Tennessee’s spring game and stopped returning calls from coaches and teammates. Within days, he entered the transfer portal and quickly landed at UCLA, a move that surprised many given the Bruins had already named Joey Aguilar their expected starter for the upcoming season. Aguilar then transferred to Tennessee soon after, creating one of the more unusual quarterback swaps in recent memory. Adding to the ripple effects, Iamaleava’s younger brother, Madden, also left University of Arkansas to follow Nico to UCLA. Madden, a four-star quarterback prospect in the 2024 class, had originally committed to UCLA before flipping to Arkansas on National Signing Day in December 2024. He enrolled at Arkansas at the start of the spring semester but chose to leave before ever playing a game for the Razorbacks.
Legal Gray Areas
The uncertainty surrounding Iamaleava’s exit from Tennessee is not just about one quarterback or one NIL deal. It highlights the bigger legal questions facing college athletics in the NIL era, where contracts often lack the structure and enforceability seen in professional sports. Professor Jodi Balsam, a nationally recognized sports law expert and former NFL counsel for operations and litigation, believes the current system is showing the cracks of a labor market without clear rules. Balsam serves as Professor of Clinical Law and Director of Externship Programs at Brooklyn Law School and also teaches Sports Law at New York University, with additional experience as a co-author of one of the leading casebooks on sports law.
“This is what happens when you have a labor market that operates somewhere between professional and amateur sports but without the protections or consistency of either,” Balsam said in an interview for this story. She explained that without collective bargaining agreements or formal unionization, there is little stopping high-profile athletes from seeking new opportunities whenever a better deal comes along. “If this were a professional league without a union, teams would be free to contract with any player on any terms, and that’s essentially what we’re seeing now in college sports,” she said.
According to Balsam, the lack of regulation creates both opportunity and risk. While top players like Iamaleava may benefit from a free market, many others face instability, unclear expectations, and limited protections. “There are marquee athletes who will absolutely capitalize on this system, but there are also many players being exploited or misled along the way,” she said. With no uniform labor structure in place and NIL deals often tied to booster collectives rather than schools themselves, enforcement remains murky at best, leaving open the question of whether programs like Tennessee could successfully hold an athlete to these agreements at all.
Litigation on the Horizon?
The uncertainty around NIL enforcement has also left the door open for schools to test how far they can go in holding athletes accountable to these deals. In the wake of Madden Iamaleava’s departure, Arkansas officials have publicly confirmed that they are exploring legal action against Madden for breach of contract, citing buyout language included in his one-year NIL agreement with the school’s collective, Arkansas Edge. Madden had only been enrolled at Arkansas since January before choosing to leave for UCLA, and reports indicate that his NIL deal required repayment of a portion of the agreement if he exited early. Arkansas athletic director Hunter Yurachek has voiced strong support for the collective’s efforts to enforce these agreements, calling such action “vital in our new world of college athletics.”
While Tennessee has not publicly confirmed any similar legal pursuit against Nico Iamaleava, there has been growing speculation about whether the school or its NIL collective could explore that option. If Tennessee’s NIL deal with Iamaleava included similar contractual protections or buyout clauses, the program could attempt to recover some of the financial investment tied to his agreement. Whether such efforts would hold up in court remains unclear given the unsettled nature of NIL contract law and the complex question of whether these agreements function as enforceable employment contracts. With little precedent to follow, any legal action from Arkansas, Tennessee, or other programs in similar situations could play a role in shaping how similar disputes are handled.
What Comes Next?
As the Iamaleava brothers settle into their new chapter at UCLA, the legal and financial fallout from their departures remains unresolved. Whether Arkansas follows through on its plans for legal action against Madden, or Tennessee chooses to do the same with Nico, could shape how future NIL contracts are structured and enforced. For now, both quarterbacks are preparing for the upcoming season, but their high-profile decisions have drawn national attention. With the House v. NCAA settlement still pending and no clear labor system in place, this situation could become an early example of how schools attempt to hold athletes accountable in the NIL era. What happens next may help define how college football handles player movement, contract disputes, and competitive balance in the years ahead.
Joseph Michael Ricco IV is a junior at the University of Texas at Austin studying sport management and government. He has experience in recruiting operations with Texas Football, training camp operations with the Kansas City Chiefs, and football data analytics with Pro Football Focus. He also publishes work on sports law topics, including salary cap, NIL, and CBAs. Joseph plans to attend law school and pursue a career in football operations, player personnel, or administration.
References
Cookston, H. (2025, April 23). Arkansas nearing legal action against Madden Iamaleava, Tennessee could pull Nico in Crossfire. Sporting News. https://www.sportingnews.com/us/ncaa-football/news/arkansas-nearing-legal-action-against-madden-iamaleava-tennessee-could-pull-nico-crossfire/9f21e62d1e34fdbea92742ca
Gregoire, W. (2025, April 12). Nico Iamaleava Highlights Problem With NCAA Sports. Stadium Rant. https://www.stadiumrant.com/nico-iamaleava-highlights-problem-with-ncaa/
Jeyarajah, S. (2025, April 23). Source of Nico IAMALEAVA’s frustration rooted in massive nil deals for Carson Beck, Darian Mensah, per report. CBSSports.com. https://www.cbssports.com/college-football/news/source-of-nico-iamaleavas-frustration-rooted-in-massive-nil-deals-for-carson-beck-darian-mensah-per-report/amp/
Low, C., Olson, M., & Rittenberg, A. (2025, April 23). Why Nico Iamaleava soured on Tennessee and ended up at UCLA. ESPN. https://www.espn.com/college-football/story/_/id/44787682/why-nico-iamaleava-left-tennessee-joined-ucla
Marcello, B. (2025, April 23). Arkansas puts departed QB Madden Iamaleava in its crosshairs by encouraging Nil Collective to recoup buyout. CBSSports.com. https://www.cbssports.com/college-football/news/arkansas-puts-departed-qb-madden-iamaleava-in-its-crosshairs-by-encouraging-nil-collective-to-recoup-buyout/
