ZEIGLER v. National Collegiate Athletic Association
3:25-cv-00226
E.D. Tenn.Jun 12, 2025Background
- Zakai Zeigler, a former University of Tennessee basketball player, seeks a fifth season of NCAA Division I men’s basketball while pursuing a graduate degree in 2025-26.
- Zeigler already played four consecutive Division I seasons and received substantial NIL (name, image, and likeness) compensation during his eligibility.
- The NCAA’s Four-Seasons Rule (Bylaw 12.8) limits student-athletes to four seasons of competition within a five-year period, regardless of academic status.
- Zeigler argues that the Four-Seasons Rule unlawfully restricts his opportunity to play and thus limits his ability to earn NIL income.
- Plaintiff moved for a preliminary injunction to stop the NCAA from enforcing the rule, claiming violations of the Sherman Act and Tennessee Trade Practices Act (TTPA).
- The NCAA opposed the motion, leading to briefing and a hearing before the court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sherman Act—Anticompetitive Restraint | Four-Seasons Rule unlawfully restricts market for student-athlete services and NIL compensation | Rule is non-commercial, pertains to eligibility, and does not control NIL compensation | Not likely to succeed—insufficient evidence of anticompetitive effects; NCAA doesn't control NIL compensation |
| Rule of Reason Applicability | Rule’s impact on labor and wages should be assessed under traditional Rule of Reason analysis | Claimed a "quick look" suffices, but later conceded Rule of Reason applies | Rule of Reason applies, but plaintiff’s evidence is insufficient |
| TTPA Violation | Rule unreasonably restrains trade under Tennessee law and state law change means all NCAA eligibility rules are illegal | State law does not create private right for injunctive relief; injury mirrors Sherman Act analysis | Not likely to succeed; no private right and mirrors Sherman Act analysis |
| Preliminary Injunction Factors | Faces irreparable harm losing NIL opportunities; public interest favors relief | Harms to others (other athletes); alleged harms are monetary; public interest doesn't support injunction | No irreparable harm shown; balance does not favor injunction |
Key Cases Cited
- Winter v. Nat. Res. Def. Council, Inc., 555 U.S. 7 (preliminary injunction standard—extraordinary remedy)
- Nat’l Collegiate Athletic Ass’n v. Alston, 594 U.S. 69 (market realities and compensation for student-athletes)
- Ohio v. Am. Exp. Co., 585 U.S. 529 (rule of reason; market effects required)
- Bassett v. Nat’l Collegiate Athletic Ass’n, 528 F.3d 426 (Sixth Circuit on NCAA rules and commercial impact)
- Standard Oil Co. v. United States, 221 U.S. 1 (restraints of trade must be unreasonable under Sherman Act)
- Nat’l Collegiate Athletic Ass’n v. Bd. of Regents of Univ. of Okla., 468 U.S. 85 (antitrust scrutiny of NCAA rules)