Former University of Tennessee point guard Zakai Zeigler is taking the NCAA to court over its “Four-Seasons Rule,” which restricts college student-athletes to four seasons of competition within a five-year period of time. This case has the potential to blow up the NCAA’s eligibility rules and may be the first to apply a Tennessee state law aimed at banning the NCAA from restricting name, image, and likeness (NIL) compensation to student-athletes.
While recently there has been a flurry of challenges to the Four-Seasons Rule, this case is unique. Zeigler did not spend time at a junior college (like Vanderbilt quarterback Diego Pavia), nor did he spend time playing in another NCAA division (like University of Wisconsin cornerback Nyzier Fourqurean). Zeigler played four consecutive seasons of Division 1 basketball at Tennessee, while completing his undergraduate degree during that time. Zeigler has said he plans to attend graduate school and is seeking a fifth year of eligibility.
Zeigler filed his lawsuit in the U.S. District Court for the Eastern District of Tennessee. He argues that the Four-Seasons Rule unjustly limits his athletic development, harms his professional prospects, and, most importantly, will prevent him from earning between $2 million and $4 million in NIL compensation if he is denied the opportunity to play in the upcoming 2025-2026 season.
NIL Compensation and Legal Claims Under Tennessee Law
He is seeking a preliminary injunction allowing him to compete, which he argues is an outcome that aligns with the NCAA’s educational mission and other existing NCAA eligibility rules, such as the redshirt rule. Zeigler’s complaint specifically calls out the NCAA’s redshirt rule, which allows athletes to compete in a fifth year under certain circumstances. According to Zeigler, this creates a discriminatory two-tier system where some athletes get to earn NIL compensation for five years, where others, like Zeigler, do not.
Zeigler’s complaint also goes on offense by attacking the NCAA’s justifications for the Four-Seasons Rule, which the NCAA has advanced in prior lawsuits. These justifications include the preservation of amateurism, the promotion of competitive balance, and the integration of athletics and education. Zeigler argues that these justifications lack merit.
For example, Zeigler highlights that the NCAA allows student-athletes to complete only 20% of their credits annually and uses a six-year graduation benchmark. Additionally, the NCAA permits student-athletes to take years off to serve in the military or serve religious missions and return without losing any eligibility. These points undermine the NCAA’s claim that limiting competition to four years promotes academic integrity.
An additional unique aspect of Zeigler’s lawsuit is its reliance on a recently enacted Tennessee law—Senate Bill 536—which clarifies that Tennessee state antitrust law applies to collegiate athletics and explicitly prohibits NCAA rules that “adversely affect an intercollegiate athlete’s ability to earn compensation” or “impact an intercollegiate athlete’s eligibility or full participation in intercollegiate athletic events.”
Broader Implications for College Sports and State Legislation
Senate Bill 536 was signed into law by Gov. Bill Lee just weeks ago, and there is currently no similar law in any other state. Whether and the extent to which the court relies on Senate Bill 536 in determining Zeigler’s fate is an open question.
Venable and its sports law team will continue to monitor Zeigler’s lawsuit, as it has the potential to disrupt college sports. If the court grants Zeigler’s request for an additional year of eligibility, numerous copycat lawsuits will be filed by athletes seeking an additional year of eligibility. Some might even seek a sixth year (or more) while pursuing graduate degrees.
Finally, if any part of the court’s decision relies on Tennessee’s Senate Bill 536, expect other state legislatures to enact similar laws to ensure that schools within their states remain competitive with Tennessee schools when it comes to college sports.
For more sports law analysis and insights, please contact the authors or visit the Venable Sports Law Group web page.