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NIL

Key legal developments in college athletics

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The influence of name, image, and likeness (NIL) rights
continues to push the boundaries of college sports in unprecedented ways. From
the ripple effects of the transfer portal to the ongoing antitrust battles in
federal court, nearly every aspect of college athletics is now touched by the
high stakes of athlete endorsements including pending litigation and a
patchwork of NIL laws and guidelines.

As we approach the midpoint of 2025, let’s review the power
plays and upsets for NIL stakeholders and consider how sports lawyers can guide
our athletes through new and evolving regulatory hurdles.

The transfer portal and shifting power dynamics

New Division I transfer rule changes were implemented to make
transferring “more flexible and streamlined,” according to the National
Collegiate Athletic Association (NCAA). Key updates included earlier
portal access, one-time transfer exceptions, and stricter academic standards
(requiring a minimum 2.0 GPA) to maintain academic integrity. These changes also
eliminated restrictions on the number of transfers an academically eligible
athlete can make during their career, provided they remain in good academic
standing.

With
that in mind, remember the name Nico Iamaleava, as a
precedent or rule could soon bear his name. His departure from Tennessee to
UCLA marks a pivotal moment in the transfer portal era. Despite leading the
Volunteers to a College Football Playoff appearance in 2024, Iamaleava announced his move to UCLA via Instagram on April
20, following a failed attempt to renegotiate his NIL deal from $2.4 million to
$4 million. Iamaleava’s decision to leave due to
compensation disputes underscores the shifting power dynamics between athletes
and programs. Notably, his move to UCLA-reportedly for a lesser NIL
deal-coincides with his younger brother, Nico, also transferring to UCLA. These
events signal a trend where top players may prioritize personal factors over
financial gain, potentially reshaping future transfer decisions and NIL
strategies.

In 2025,
with his transfer to UCLA, Nico Iamaleava will still
be considered a redshirt sophomore, as he has three years of eligibility
remaining under the NCAA’s five-year
clock rule.

The
growing influence of NIL negotiations on player movement has further
repercussions. At UCLA, Nico Iamaleava is expected to
take on the starting quarterback role for the 2025 season, signaling the
departure of Bruins quarterback Dermaricus Davis, a
four-star recruit ranked as the third-best QB prospect from California in the
2024 recruiting class. This high-profile move highlights the volatility of the
college landscape, as coaches seeking to build a legacy may now face new risks
and rewards when connecting with marquee players they did not recruit.

Eligibility rules, legal challenges and antitrust implications

NIL deals and antitrust laws are also influencing player eligibility. In an April court decision
involving Jett Elad, a 24-year-old Division I transfer to Rutgers University, a
U.S. district judge granted a preliminary injunction allowing Elad to continue
playing for the Scarlet Knights in the fall, despite having exhausted his NCAA
eligibility.

U.S. District Judge Zahid N. Quraishi concluded that NCAA
eligibility rules – which limit athletes to four seasons of intercollegiate
competition, including junior college seasons – are problematic under antitrust
law. Division I football players are part of a labor market and can secure
lucrative endorsement deals, using college football as a platform for the NFL.

“[The] injunction is potentially Elad’s only opportunity to
complete his Division I career and transition into the NFL,” wrote Judge
Quraishi.

The court’s injunction prevents the NCAA from declaring Elad
ineligible for the upcoming season, enhancing
his chances in the 2026 NFL draft.
This legal decision may also spark
further discussion about the evolving nature of college sports and their
increasing resemblance to professional leagues or minor league systems.

The House settlement: Roster limits and revenue sharing

The interconnectedness of eligibility, the transfer portal, and
the billions of NIL dollars at stake all hinge on the pending settlement in House v. NCAA.

House v. NCAA is a federal class action antitrust lawsuit
filed in the Northern District of California by college athletes against the
NCAA and major conferences (ACC, Big Ten, Big 12, Pac-12, and SEC). The
plaintiffs allege that NCAA rules unlawfully restricted athletes from earning
NIL compensation, thus violating antitrust laws. The settlement also
encompasses related cases, including Hubbard v. NCAA and Carter v.
NCAA
.

Senior District Judge Claudia Wilken has been presiding over the
settlement for months, meticulously reviewing every detail to ensure the new
rulebook is properly finalized. On April 23, 2025, she introduced a significant
obstacle that could jeopardize the agreement. Judge Wilken demanded that the
parties revisit the section of the proposed $2.8 billion settlement pertaining
to roster limits a provision several schools have already begun to implement.

The NCAA currently limits the number of scholarships a team can
offer but does not restrict total roster size. For example, FBS football
programs are allowed 85 scholarships but typically carry up to 120 players,
including walk-ons. Under the settlement, new roster limits would cap the total
number of athletes per team, though exact figures have yet to be finalized.

This change is designed to control financial exposure for
schools, which under the settlement would share up to 22% of their athletic
revenue directly with athletes. Fewer roster spots would mean fewer athletes
splitting those funds. However, the proposal has drawn criticism for
potentially reducing opportunities for non-scholarship athletes, especially
walk-ons, and raising Title IX concerns if women’s sports face disproportionate
cuts or unequal revenue-sharing benefits.

Judge Wilken warned that unless these issues are addressed, the
court may withhold final approval of the $2.8 billion settlement, giving all
sides 14 days to contact their mediator and return to the bargaining table.

More hurdles to clear

These are just some of the many issues challenging the NCAA and
the state of college athletics. Until Congress establishes a federal framework,
this patchwork of rules will continue to govern athletic activity both on and
off the field.

Stakeholders need support with strategy and decision-making, and
sports lawyers can provide our athletes and schools with the guidance necessary
to ensure compliance. This will help maintain the integrity of college sports
and suggest innovative ways to move forward in this new, NIL-driven era of
athletic competition.



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NIL

Kyle Whittingham reveals if he had any hesitation on Michigan with controversy, investigation around program

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Michigan has been in hot water the past few years. In 2023, the football program was exposed for participating in an illegal sign-stealing scheme. This year, the school fired head coach Sherrone Moore after he was charged with felony third-degree home invasion and two misdemeanors.

Now, the school is thoroughly investigating its entire football program for any other signs of misconduct. Nonetheless, the program is seemingly heading in a new direction after hiring Kyle Whittingham to be its next head coach.

Whittingham is a well-respected figure in the college football community and was Utah‘s head coach from 2005-25. During his introductory press conference on Sunday, Whittingham revealed whether he hesitated to join the Wolverines due to the controversy surrounding Michigan.

“I didn’t have any hesitation. There’s some issues, missteps that are being taken care of, but the key is the players are solid,” Whittingham said. “The players here are rock-solid. None of those issues, none of those things that we’re dealing with involve the players. And to their credit, they just kept grinding and kept after it.

“I’m so impressed with that because there was a lot of distractions and a lot of adversity, I guess you can say. But, I got no doubt that everything’s going to be handled properly. We’ll see. I’m not knowledgeable enough and privy enough to exactly what’s going on in the details, but I’ve got full confidence that we’ll come out of this just fine.”

Michigan doesn’t have a talent problem. The team posted a 9-3 record in the regular season, including a 7-2 mark in conference play. The Wolverines are expected to return several key players as well, most notably quarterback Bryce Underwood.

Underwood is a freshman this season, but started in all 12 of Michigan’s regular-season games. While Underwood didn’t regularly dominate opponents, he showed promising flashes and will be pivotal to Michigan’s future success.

Kyle Whittingham isn’t allowing any administrative measures to affect his relationships with Michigan’s players. After all, he knows those relationships will be the key to a successful first year in Ann Arbor.

“My culture is going to be with the players. What I’m concerned with is the players,” Whittingham said. “I certainly know the general gist of what transpired, in this series of, I guess we’ll call them unfortunate events, but not really fazing me.

“The players are a great group of kids. They’re hungry. They got a lot of want-to in them and that’s where my focus is. I focus on coaching the team, and everything else be handled in due time and in due process.”



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Kyle Whittingham introduced as Michigan football coach

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Updated Dec. 28, 2025, 11:53 a.m. ET

Highlights from the press conference Sunday to introduce Kyle Whittingham as Michigan’s new head football coach:

➤On how someone from the outside will reset the culture: “My culture is going to be with the players.” Whittingham said he knows the “gist” of what transpired in the investigation and firing of former head coach Sherrone Moore, but says his focus is on the players and hopes the university and program will handle the rest.

➤On his conversation with starting quarterback Bryce Underwood: “Quarterbacks have to have that ‘it’ factor, and he has that ‘it’ factor.” Believes that Underwood has potential and can’t wait to work with him.



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The Clemson Insider

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CLEMSON — From time to time, we have heard Dabo Swinney say, “the proof is in the pudding.”

During Clemson’s run from 2015-’20 in the College Football Playoff, there was plenty of proof of Clemson having an elite football program. The argument was strong — 79 wins, 6 ACC Championships, 6 College Football Playoff appearances, 4 National Championship Game appearances and 2 National Championships.

However, the same argument can now be made that the Clemson Football program is no longer an elite program. And like Swinney says, “the proof is in the pudding.”

Since 2021, the Clemson Football Program has 47 wins, 2 ACC Championships and 1 CFP appearance and that is it.

Now, it is probably not fair to expect the Tigers to play for a national championship in each of the last five years like it did from 2015-’19. However, it is fair to expect the program to compete for one, and right now that is not really happening. And Dabo Swinney knows it.

You could see the look of despair on his face following Saturday’s embarrassing performance to Penn State in the Pinstripe Bowl. A game in which the Tigers did not look like a competent football team.

There was miscommunication. There was questionable play calling on both sides of the ball. There was a lack of execution. There were a lot of things that went wrong.

It was a disaster.

And yes, Clemson was playing without a lot of players, but so was Penn State, and the Nittany Lions were coached by an interim head coach, plus a staff full of coaches who were leaving for other programs after the game. And Penn State looked way more competent as a football team and program.

Do you want to know why Penn State dominated the Tigers in the second half of Saturday’s game at Yankee Stadium in New York, N.Y.? It had better depth than Clemson.

Why is that true?

Because Penn State, despite their struggles this season, has invested more in trying to build its roster through the transfer portal and NIL, way more than Clemson has at least.

And, as Swinney says, “the proof is in the pudding.”

When comparing the Clemson program in the pre-NIL-and-transfer-portal era to the current era, there is no comparison. The Tigers won 91.5 percent of their games in the previous five-year stretch. In the last five years since the transfer-portal and NIL took over college athletics, Clemson has won 70.1 percent of its games.

However, in the previous five-year stretch, when playing the top programs in college football, the Tigers were 14-4 (.778). In the last five seasons, they are 1-8 (.125), and that is the most telling part of all of this.

I can keep going. Clemson was 38-3 (.927) in ACC play from 2016-’20, and in the last five seasons, 29-11 (.723) which includes two 4-4 campaigns and two consecutive losses to Duke. If Duke had lost to Clemson in men’s basketball in consecutive games, I can promise you Jon Scheyer would be on the hot seat in Durham.

Guess what? After Saturday’s disappointing loss, which wrapped up an extremely disappointing season, the seat that Dabo Swinney has sat on for so long at Clemson is hot. If he does not get things turned around soon, it’s going to be too hot for him to sit on.



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$5.3 million QB explains career decision to return to college football

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The highest-valued player in college sports officially announced his plans to delay a professional career and return to school for the 2026 season. This decision secures the most vital position on the field for the Texas Longhorns as they prepare for the Citrus Bowl and look toward a future conference title run.

Holding a massive $5.3 million valuation and the top spot in the On3 NIL 100, the redshirt sophomore faced intense speculation regarding the NFL Draft. Many analysts projected him as a potential early selection despite a season that began with mixed results. However, the signal-caller opted to prioritize further development at the collegiate level over immediate professional opportunities.

His return ensures continuity for an offense that found its rhythm late in the year. By bypassing the draft, the program retains a leader who guided the team to nine wins and a victory over a bitter in-state rival to close the regular season. The choice reflects a desire to complete unfinished business before making the leap to the next level.

Texas Longhorns QB discusses development and future in Austin

Arch Manning addressed the media ahead of the postseason matchup against the Michigan Wolverines, clarifying why he chose to stay in Austin. The decision comes after a season where he completed 61.4 percent of his passes for 2,942 yards. Manning emphasized that his growth on the field was the primary factor in postponing his NFL entry.

“I felt like I developed a lot this year, especially towards the back half, and I want to keep it going… There’s no reason to leave,” Manning said. “I feel like I got a lot more football left to play, and I’m excited to still be a part of this team.”

Texas Longhorns quarterback Arch Manning

Texas Longhorns quarterback Arch Manning faced scrutiny at the start of the season, but the 21-year-old signal-caller finished the season with a 27-17 win over the then-undefeated Texas A&M Aggies. | Scott Wachter-Imagn Images

The quarterback’s performance improved significantly following early setbacks against the Ohio State Buckeyes and Florida Gators. He finished the regular season with 24 passing touchdowns and added eight scores on the ground. His dual-threat ability was on display during the regular-season finale, where he accounted for two touchdowns to help defeat the then-undefeated Texas A&M Aggies.

Texas Longhorns quarterback Arch Manning

Texas quarterback Arch Manning and the Longhorns will conclude their 2025 campaign against the Michigan Wolverines in the Citrus Bowl on New Year’s Eve. | Scott Wachter-Imagn Images

Texas Longhorns head coach Steve Sarkisian supported the move. He noted the mental and physical maturity Manning demonstrated during his first full year as the starter. The return of the team captain fortifies a roster that will face a nine-game SEC schedule in 2026, including a highly anticipated rematch with Ohio State in September.

Manning and his teammates are currently focused on their upcoming opponent in Orlando. A victory would secure a 10-win season and generate significant momentum heading into the offseason. The Longhorns will face the Michigan Wolverines in the Citrus Bowl in Orlando, Florida, on Dec. 31 at 3 p.m. ET on ABC.

Read more on College Football HQ



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How Kyle Whittingham has previously attacked the transfer portal

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Now that everyone has had some time to process the hiring of former Utah head coach Kyle Whittingham, it is time to turn our attention to business.

Whittingham agreed to a five-year contract on Friday and was put on a plane straight to Orlando to start building relationships with the players. He’s got to act fast, as the transfer portal opens on Jan. 2 and players will have some quick decisions to make.

What makes Whittingham a fascinating hire is his ability to do more with less. Coming into the 2025 season, Utah was expected to be working with an NIL operating budget of $8 million. For comparison, according to On3’s Pete Nakos, the Wolverines were expected to cross the $20 million threshold.

Obviously, a lot of that money is allocated to high school recruits, but with the wild west that is the transfer portal, Whittingham could be looking to fill his roster via the portal to compliment the young roster Michigan put on the field last season.

In 2025, Utah was ranked 37th in national transfer portal rankings, according to 247Sports, bringing in 22 new players. He also lost 31 players. For reference, Michigan was ranked 30th with 17 incoming transfers.

The highlights of the portal for the Utes’ was former New Mexico quarterback Devon Dampier and Washington State running back Wayshawn Parker, who both helped Utah’s offense drastically. Dampier followed offensive coordinator Jason Beck to Salt Lake City and was the Big 12 Newcomer of the Year after throwing for 2,768 yards and 12 touchdowns.

Meanwhile, Parker was ranked the No. 2 running back in the portal after a terrific 2024 season at Washington State where he rushed for 735 yards (5.4 yards per carry) and four touchdowns. With the Utes this year, Parker ran for 931 yards and six touchdowns.

On defense, Utah received solid play from UC Davis transfer cornerback Blake Cotton. In seven starts, he totaled 25 tackles (two for loss) and seven pass breakups.

However, outside of those three, there was not much other production. The year before showed a similar trend, as Whittingham brought in 12 transfers via the portal while losing 25. Utah was ranked 32nd in the country in transfer portal rankings, with the biggest get being wide receiver Dorian Singer. The former 1,000-yard receiver started all 12 games in 2024, leading Utah with 53 catches and 702 yards to go along with one touchdown.

Most interestingly, of the 22 commits in 2025, six were wide receivers, four were running backs and four were cornerbacks. Of the 12 2024 commits, three were wide receivers, three were edge rushers and three played in the secondary. With a majority of the transfers coming at the same few positions, it appears Whittingham uses the portal to fill holes and build depth more so than just getting the best guys available.

It will be interesting to see how Whittingham plans to utilize the portal in his first season at Michigan, especially with the expectation the Wolverines will lose some of their roster once the coaching staff appears to form. At the very minimum, he will need to replace some of Michigan’s receiving corps, tight end room and secondary with players leaving and those being weak spots on the team this past season.

But with a larger NIL budget and resources, the Michigan brand and the desire to make a splash right away, Whittingham could go away from his typical playbook and hit the portal hard.



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Bowl game star leaving team to enter college football transfer portal

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College football bowl season isn’t what it was a decade ago. In the modern age of the sport, most of the significance and attention sits on the 12-team College Football Playoff.

That hasn’t stopped the postseason from delivering plenty of exciting moments and some very competitive games. Look no further than Saturday’s slate. Five of the eight matchups came down to a single possession.

One of the comebacks of the year fell just short in the Isleta New Mexico Bowl. North Texas prevailed over San Diego State, 49-47, but not without plenty of drama. Trailing 49-20 entering the fourth quarter, the Aztecs went on a 27-7 run, including a punt return for a touchdown.

San Diego State’s final score came with just one second remaining, allowing North Texas to run out the clock on the ensuing onside kick. The result moved the Mean Green to 12-2, the best record in program history, and more wins than in their last two years combined.

Coming out of the game, North Texas is having a hard time celebrating after taking a few transfer portal hits. The school previously lost its head coach, Eric Morris, to Oklahoma State.

Breakout Running Back Moving On To Transfer Portal

On Saturday evening, redshirt freshman running back Ashton Gray announced his decision to transfer after two seasons at North Texas, per On3’s Hayes Fawcett.

Gray came out of nowhere to play a big role in the New Mexico Bowl. He saw increased playing time with Makenzie McGill and Kiefer Sibley unavailable. Gray finished the game with a career-high 16 carries for 152 yards and 2 touchdowns, while adding one reception for nine yards.

The Arkansas native scored twice in the first half, including a 51-yard scamper early in the second quarter that put North Texas up 28-13. His first touchdown gave the Mean Green a 14-7 advantage that they would never relinquish despite San Diego State’s late rally.

Gray entered the game with 42 carries for 225 yards and 3 touchdowns on the season. That just goes to show how impressive his final outing of the fall truly was.

Including the bowl game, Gray totaled 40 carries for 283 yards and 4 touchdowns in his last four appearances.

Gray signed with North Texas as a three-star prospect in the 2024 class. He redshirted during his first season with the program. Gray was recruited by former head coach Eric Morris and could potentially fit in at Oklahoma State.

The 6-foot-0, 208-pound running back will have three seasons of eligibility remaining.

Gray was the Little Rock Touchdown Club State Player of the Year and an all-state selection during his senior season at Marion High School in 2023.

North Texas has multiple starters expected to enter the portal, including quarterback Drew Mestemaker and running back Caleb Hawkins.

Read more on College Football HQ

• College Football Playoff team loses key starter to NCAA transfer portal

• College Football Playoff team loses former starter to transfer portal

• College Football Playoff team has taken 3 major hits in trenches via transfer portal

• College football team set to be without nearly 20 players for upcoming bowl game



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