Last week, Ole Miss quarterback Trinidad Chambliss secured a preliminary injunction from a Mississippi state court judge, clearing the way for him to compete in the 2026 season, effectively granting him a sixth year of NCAA eligibility. Chambliss is expected to receive a NIL package worth $5–6 million.
At the heart of the dispute is whether the NCAA lawfully denied him a "medical redshirt" for the 2022 season he spent at Division II Ferris State. NCAA student-athletes are generally permitted four seasons of competition within a five-year period. The NCAA may, however, grant a medical redshirt to athletes who are unable to compete in a given season due to a season-ending injury or illness.
Chambliss did not follow the same playbook used in many prior eligibility lawsuits, which have typically challenged the NCAA's rules as unlawful restraints under federal antitrust law. As the growing number of unsuccessful cases demonstrate, claims under the Sherman Act carry a high burden of proof, particularly in demonstrating that the NCAA's eligibility restrictions produce an anticompetitive effect in a properly defined market.
Instead, Chambliss argued that under principles of contract law, the NCAA failed to apply its bylaws in good faith when it denied Chambliss' request for a medical hardship waiver. His approach was notable because student-athletes are not direct parties to contracts with the NCAA. To overcome that obstacle, Chambliss argued that he qualifies as an intended third-party beneficiary of the contracts between the NCAA and its member institutions.
Chambliss's Breach of Contract Claim
Chambliss' lawsuit alleges that medical conditions related to persistent respiratory issues caused by chronic tonsillitis prevented him from competing during the 2022 season, and Ferris State treated that year as a redshirt season. In 2024, he underwent treatment that resolved those conditions. Chambliss then transferred to Ole Miss to compete in the 2025 season, according to the lawsuit, with the understanding that his 2022 season would not count against his eligibility. After a breakthrough year—coming off the bench to lead Ole Miss to the semifinals of the College Football Playoff—the NCAA informed Chambliss that he had not submitted sufficient medical documentation to substantiate his prior condition. As a result, the NCAA declined to grant him a medical redshirt for the 2022 season.
Chambliss moved quickly, filing suit in Mississippi state court. Many observers expected him to challenge the NCAA's medical redshirt rules on antitrust grounds. Instead, he advanced a breach of contract theory. Specifically, Chambliss contended that NCAA member institutions agree to abide by the NCAA's bylaws and to defer eligibility determinations to the NCAA's authority. In return, the NCAA is obligated to apply those bylaws faithfully and in accordance with the standards they prescribe when adjudicating medical redshirt requests. According to Chambliss, the NCAA failed to uphold its contractual obligations by arbitrarily rejecting his medical redshirt request, which included supporting medical records and opinions from his treating physicians.
One obstacle to Chambliss' theory was that he is not a direct party to any contract between the NCAA and its member institutions. To overcome that hurdle, he argued that student-athletes are intended third-party beneficiaries of those contracts and are, therefore, entitled to enforce them. As an intended beneficiary, Chambliss contended that he was owed the implied duty of good faith and fair dealing that Mississippi law reads into every contract. On that basis, he maintained that the NCAA's alleged failure to apply its bylaws in good faith entitled him to a medical redshirt for the 2022 season at Ferris State—and, in turn, an additional year of eligibility.
Chambliss Prevails, Potentially Creating a New Playbook for Future Lawsuits
The court agreed with Chambliss. On February 12, 2026, Judge Whitwell of the Lafayette County Chancery Court issued a preliminary injunction prohibiting the NCAA from deeming Chambliss ineligible for the 2026–27 season. In doing so, the court concluded that Chambliss had demonstrated a likelihood of success on the merits of his contract-based claims and that he would suffer irreparable harm absent injunctive relief.
Although the ruling is preliminary and fact-specific, its significance may extend beyond Chambliss' individual eligibility dispute. For years, student-athletes challenging NCAA eligibility rules have largely relied on federal antitrust theories, arguing that the NCAA's rules constitute unlawful restraints of trade. Those claims have faced substantial doctrinal and evidentiary hurdles. Here, rather than attacking the legality of the NCAA's medical redshirt rules, Chambliss targeted the NCAA's interpretation and application of those rules. By framing the dispute as one of contractual compliance—arguing that the NCAA failed to follow its own bylaws in good faith—he avoided the complex economic analysis required under the Sherman Act.
The court's willingness to entertain Chambliss' third-party beneficiary theory signals that student-athletes may have a new playbook for challenging NCAA decision-making. If other courts prove receptive, future eligibility disputes may turn less on sweeping antitrust attacks and more on whether the NCAA followed its own rules, applied them consistently and acted in good faith. Such a shift would not dismantle NCAA authority—but it could make that authority more judicially accountable and significantly lower the practical barriers to bringing suit, particularly in state courts applying traditional contract principles.
If you or your company would like to talk about the shifting strategy around NCAA eligibility rules, please contact the authors or visit the Venable Sports Law team's web page and subscribe to Chalk Talk here.