Walker v. National Collegiate Athletic Association
3:25-cv-00514
| M.D. La. | Jul 1, 2025Background
- Plaintiff Rylen Walker, a student-athlete, challenged NCAA Division II eligibility rules counting junior college play against the four-year eligibility cap.
- After a recent district court decision (Pavia) found similar Division I rules violated the Sherman Act, the NCAA issued a waiver not counting JUCO seasons, but only for Division I.
- Walker sought a preliminary injunction, arguing the same policy should apply to Division II, affecting his eligibility for the 2025–2026 season.
- The NCAA denied Walker’s request, citing longstanding division-specific rules and Walker's prior knowledge that his JUCO play would count against his eligibility.
- The Court ordered expedited, targeted briefing limited to whether Walker met the irreparable harm prerequisite for injunctive relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is there irreparable harm to Walker if the injunction is not granted? | Delay justified by evolving NCAA rules and recent Pavia decision; acted diligently once internal options exhausted. | Walker delayed unreasonably; knew eligibility rules since 2022, and could have brought the suit much earlier. | No—Walker unreasonably delayed, undermining a claim of irreparable harm. |
| Does a mandatory injunction restoring eligibility meet the high standard required? | Seeks extraordinary relief due to unique, shifting legal landscape and NCAA's inconsistent application. | Mandatory injunctions are disfavored, especially when plaintiff seeks to alter, not preserve, the status quo. | No—the relief sought is disruptive, not status-preserving, and standards are not met. |
| Does seeking extra-judicial solutions excuse delay in seeking injunctive relief? | Delay reasonable due to pursuing NCAA waivers and assessing Division I transfer options. | Speculative non-judicial options do not justify delay, as per case law. | No—pursuit of non-judicial solutions does not excuse delay. |
| Is there a substantial likelihood of success on the merits? | Walker argues NCAA rules are anticompetitive as found in Pavia. | NCAA cites division-specific governance and lack of automatic waiver to DII. | Not reached; failure to show irreparable harm is dispositive. |
Key Cases Cited
- Sierra Club, Lone Star Chapter v. F.D.I.C., 992 F.2d 545 (5th Cir. 1993) (four-prong test for preliminary injunction standard)
- Martinez v. Mathews, 544 F.2d 1233 (5th Cir. 1976) (mandatory injunctions require a higher showing)
- Boire v. Pilot Freight Carriers, Inc., 515 F.2d 1185 (5th Cir. 1975) (denying preliminary relief due to delay)
- Citibank, N.A. v. Citytrust, 756 F.2d 273 (2d Cir. 1985) (delay undercuts irreparable harm in injunction context)
- Tough Traveler, Ltd. v. Outbound Prod., 60 F.3d 964 (2d Cir. 1995) (delayed pursuit of relief weighs against injunction)