By Feiting Li, of FSU
On January 15, 2026, the U.S. District Court for the Middle District of Tennessee denied a motion for a preliminary injunction filed by several NCAA football players against the NCAA. The plaintiffs challenge the NCAA’s eligibility framework, including the five-year clock, the four-season limit, and the redshirt exception. They sought a fifth season of competition, not merely the four-game participation allowance available under the football redshirt rule. To obtain a preliminary injunction (PI), plaintiffs had to satisfy four factors: (1) likelihood of success on the merits, (2) irreparable harm, (3) balance of equities, and (4) the public interest. Because a PI is an extraordinary remedy, failure on any one prong can defeat the request. The court denied the PI request primarily because plaintiffs did not show a likelihood of success, and the balance of equities and public interest also weighed against an injunction. The analysis below summarizes the court’s reasoning.
House Release Issue
The NCAA argued that the relief plaintiffs sought was barred by the class-action settlement release in House, which the NCAA characterized as covering challenges to NCAA rules governing how long athletes may remain eligible to receive benefits during a five-year eligibility period. Plaintiffs responded that, although they are members of the settlement class, the release should not be read to foreclose this suit because House centered on financial benefits (such as NIL-related restrictions and scholarship-related rules), while this case seeks extended playing eligibility. Plaintiffs also cited other cases to argue that settlement releases should not be construed broadly to bar later, distinct suits absent clear language. The court did not resolve the release issue at the PI stage, explaining that it required additional briefing, and instead decided the motion on the PI factors.
Likelihood of Success
The court held that plaintiffs had to show a likelihood of success on their Section 1 Sherman Act claim. To do this, plaintiffs had to show an agreement that unreasonably restrains trade in a relevant market. Under the rule of reason, plaintiffs must show a substantial anticompetitive effect in the relevant market. The NCAA then must offer a procompetitive rationale. The burden then returns to plaintiffs to show the same benefits could be achieved through a substantially less restrictive alternative. The NCAA argued that the eligibility rules are noncommercial, but the court rejected that view, noting that in the NIL era eligibility directly affects athletes’ ability to earn NIL and receive school payments, so the Sherman Act can apply. However, plaintiffs failed to show a substantial anticompetitive effect, even though the court accepted Division I football as a labor market. Plaintiffs did not offer sufficient evidence of harm to the market, and the House settlement’s roster limits and compensation caps further undermined their argument that extending eligibility would increase overall output or compensation. Moreover, the court found that plaintiffs failed to rebut the NCAA’s procompetitive rationale or show that the same benefits could be achieved through a substantially less restrictive alternative. The court concluded that this failure weighed heavily against granting a preliminary injunction.
Irreparable Harm
Plaintiffs argued that losing a season of eligibility would cause irreparable harm to their athletic careers, including lost opportunities to compete, develop, and generate film and exposure. The NCAA countered those plaintiffs delayed seeking relief, that lost NIL earnings are compensable with money damages, and that plaintiffs could not show they would have roster spots next season. The court acknowledged the harm had a speculative element, but it concluded that, once a season passes, the lost opportunity to play cannot be restored. The court therefore found plaintiffs made at least some showing of irreparable harm.
Balance of Equities & Public Interest
Plaintiffs argued that an injunction would impose little burden because it would apply to only a small number of athletes and would promote fairness. The court was not persuaded. Given the weak showing on likelihood of success, the court concluded that competitive fairness did not tip the scales in plaintiffs’ favor. The NCAA also argued that granting a PI could invite similar requests and create administrative and competitive disruptions. In addition, the court credited concerns that allowing these athletes to occupy roster spots and receive benefits for an extra season could affect other players under roster limits and compensation caps. The court concluded that both the balance of equities and the public interest weighed against injunctive relief.
Why It Matters
Since NIL began in 2021, the economics of college football have shifted, and the proposed House settlement (June 2025) further accelerates that shift by allowing direct school payments while also imposing roster limits and caps on direct pay, alongside third-party NIL. In that setting, eligibility rules function not only as participation rules but also as market access rules: they shape who can remain in Division I football long enough to keep a scholarship, earn NIL compensation, and potentially receive direct school payments. That is why Patterson matters. The plaintiffs argue that the NCAA’s eligibility limits end their chance to play and earn an additional season.
Reference
Patterson v. National Collegiate Athletic Association, No. 3:25-cv-00994 (M.D. Tenn.
