Venable's Sports Law group previously wrote about former University of Tennessee point guard Zakai Zeigler's lawsuit against the NCAA over its "Four-Seasons Rule," which restricts college student-athletes to four seasons of competition within a five-year period of time. On June 12, 2025, the United States District Court for the Eastern District of Tennessee denied Zeigler's request for a preliminary injunction, where he sought to immediately suspend the NCAA's Four-Seasons Rule to make him eligible to compete this upcoming 2025–2026 season.
Things started favorably for Zeigler. The court rejected the NCAA's position (which it has consistently raised in other cases) that all eligibility rules, including the Four-Seasons Rule, are not commercial in nature and thus fall outside the bounds of antitrust law. The court reasoned that "the Four-Seasons Rule, which places limits on participation in Division I basketball, at least implicates commercial activity and has some commercial impact. The Sherman Act therefore applies."
But from there, things went downhill for Zeigler. The court found that his expert's analysis was flawed because he narrowly focused on just "the labor market for athlete services in NCAA Division I men's basketball" and did not account for the fact that the NCAA "does not control who receives NIL compensation." In other words, "while the Four-Seasons Rule may control who is eligible to play Division I basketball, limiting the labor side of the market, [the NCAA] does not control who receives NIL compensation, the wage side of the market." Notably, the court acknowledged in a footnote the recently approved House v. NCAA settlement, which provided for new NCAA rules permitting schools to pay student-athletes directly. Unfortunately for Zeigler, the settlement was approved after his request for preliminary injunction had been filed.
Next, the court rejected Zeigler's claims based 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." Instead of addressing the merits of Zeigler's argument that this new law rendered the NCAA's eligibility rules illegal in Tennessee, the court dismissed the argument because the law does not authorize private causes of action and instead leaves enforcement of the law to the state attorney general.
Finally, worth noting, the court held that Zeigler failed to show that granting his request would serve the public interest. The court pointed out that there are only so many roster spots available for each Division I basketball team, and allowing Zeigler (and others similarly situated) to play an additional year would take away opportunities for current players and incoming high school recruits. To the extent Zeigler is ultimately able to prevail at trial, the court reasoned that his asserted harms boil down to lost NIL payments, which could be adequately addressed by money damages instead of an injunction.
In sum, the ruling leaves the NCAA's Four-Seasons Rule intact and underscores the challenges of using antitrust litigation to reform college sports. In the court's words: "This Court is a court of law, not policy. What the NCAA should do as a policy matter to benefit student athletes is beyond the reach of the Sherman Act and [state law] and by extension, this Court."
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