By Dr. Kyle Conkle, on UNA
As the NCAA continues to navigate the shifting landscape of athlete compensation, Brantmeier & Joint v. NCAA represents the next significant chapter in the ongoing legal redefinition of amateurism. Filed in 2024 and certified as a class action in 2025, the case challenges the NCAA’s long-standing restrictions on prize money earnings in Division I tennis. While the lawsuit is still in its early procedural stages, the court’s decision to grant class certification signals that the NCAA’s control over non-institutional athlete earnings may soon face heightened antitrust scrutiny.
Reese Brantmeier, a women’s tennis player at the University of North Carolina, and Maya Joint, a competitor for the University of Texas, brought suit against the NCAA in the U.S. District Court for the Middle District of North Carolina. The plaintiffs contend that the NCAA’s restrictions on prize money earned in non-collegiate tennis tournaments violate Section 1 of the Sherman Antitrust Act by unreasonably restraining trade in the market for NCAA Division I tennis athletes.
Under current NCAA bylaws, tennis players may accept up to $10,000 per year in prize money before enrollment, along with amounts covering their “actual and necessary expenses.” Once enrolled in college, however, any prize money exceeding those expenses renders them ineligible to compete in Division I. This rule has required many elite junior players to forfeit earnings to maintain NCAA eligibility. The plaintiffs argue that such restrictions suppress athletes’ ability to profit from their individual labor and talent in ways that would be permissible in any other market. Their complaint seeks both injunctive relief, to end the restriction, and monetary damages for forfeited prize money.
The central legal issue in Brantmeier is whether the NCAA’s prize money rules constitute an unreasonable restraint of trade under Section 1 of the Sherman Act. The Brantmeier court’s July 2025 decision, however, focused solely on whether the case met the procedural requirements for class certification under Rule 23 of the Federal Rules of Civil Procedure. To proceed as a class action, the plaintiffs had to show numerosity, commonality, typicality, and adequacy of representation under Rule 23(a), and predominance and superiority under Rule 23(b)(3) for the damages class. Judge Loretta Biggs granted the plaintiffs’ motion for class certification, holding that the case met all Rule 23 requirements.
The court found that the proposed class of approximately 12,000 Division I tennis players since March 2020 was sufficiently large and cohesive to satisfy numerosity and commonality. Each class member was affected by the same NCAA rules, and the central question of whether or not those rules violate antitrust law could be resolved uniformly across the class. For typicality and adequacy, the court concluded that Brantmeier and Joint experienced the same alleged injury of lost/forfeited prize money as other athletes and had no conflicts of interest with the class. Under Rule 23(b)(2), the court certified an injunctive class seeking to enjoin the NCAA from enforcing its prize money rules. It also certified a Rule 23(b)(3) damages class, rejecting the NCAA’s argument that individualized calculations of lost prize money would defeat predominance. The court emphasized that liability questions were common to all members, and that variations in damages did not preclude certification.
With this decision, the court appointed Brantmeier and Joint as class representatives and authorized their attorneys to act as class counsel. The ruling set the stage for a substantive trial, currently scheduled for summer 2026. The Brantmeier certification order does not determine whether the NCAA’s rules are unlawful, but it represents a critical procedural victory for athlete plaintiffs. Class certification substantially raises the stakes for the NCAA by consolidating thousands of potential claims into a single action and exposing the association to broad injunctive relief and potential damages. Legally, the case tests how far courts are willing to extend Alston’s reasoning beyond education-related benefits into the realm of direct athletic compensation. If the plaintiffs succeed, the precedent could erode the NCAA’s ability to justify compensation restrictions in any sport where athletes can earn prize money or performance income outside of their collegiate participation.
If the plaintiffs ultimately prevail, Brantmeier could fundamentally reshape the NCAA’s regulatory framework in four main ways: policy reform, precedent expansion, operational adjustments and ethical considerations. Regarding policy reform, the NCAA may be forced to eliminate or significantly loosen prize money restrictions, potentially allowing student-athletes to retain all competition earnings without jeopardizing eligibility. With precedent expansion success in Brantmeier could encourage similar suits in other individual sports, expanding the reach of antitrust law into new corners of collegiate athletics. Pertaining to operational adjustments, compliance departments would need to develop new systems for monitoring and reporting athlete income while maintaining competitive balance and institutional integrity. And lastly, the case raises questions about equity in the sense of whether expanding financial opportunities benefits all athletes or primarily advantages those with early access to high-level tournaments.
Even if the NCAA manages to defend the rule under a “rule of reason” analysis, the scrutiny alone may prompt preemptive reform. The association continues to face a delicate balancing act: preserving an identity rooted in amateur competition while adapting to a legal environment that increasingly treats athletes as market participants with enforceable economic rights.
Brantmeier & Joint v. NCAA stands as a symbol of the continued legal erosion of the NCAA’s amateurism model. By granting class certification, the court has affirmed that the question of whether prize money restrictions unlawfully suppress athlete compensation deserves full examination under federal antitrust law. Whether or not the plaintiffs ultimately prevail, Brantmeier ensures that the conversation around fairness, freedom, and the economics of collegiate competition will remain at the forefront of sport governance for years to come.
