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Diego Pavia, JUCO Plaintiffs Seek Another Year of College Football

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As he and the Vanderbilt Commodores prepare to play the Iowa Hawkeyes in Wednesday’s ReliaQuest Bowl, quarterback Diego Pavia and 26 other former JUCO football players on Friday asked a federal judge in Tennessee to let them play in 2026 and potentially 2027.

Through attorneys Ryan Downton and Salvador Hernandez, Pavia’s group wants Chief U.S. District Judge William L. Campbell Jr. to issue a temporary restraining order and preliminary injunction that would block the NCAA from enforcing applicable eligibility rules pending a final judgment in Pavia v. NCAA. Final judgment means the case would be completed at the trial court level and appealable; no trial date has been set yet for Pavia v. NCAA, with the two sides suggesting trial dates to Campbell ranging from June 2026 to February 2027.

Pavia’s group desires for former JUCO football players to be able to compete in D-I “without regard to years of eligibility or seasons of competition at junior colleges.” The NCAA limits eligibility in one sport to four seasons of intercollegiate competition—including JUCO and D-II competition—within a five-year period. It also generally restricts former JUCO players to three years of D-I football. Pavia has proposed that the D-I eligibility clock begin when a player first registers at an NCAA member school, not when they first register at a “collegiate institution,” which includes non-NCAA schools.

In a related antitrust litigation brought by Pavia’s attorneys, Vanderbilt senior linebacker Langston Patterson is among players suing the NCAA over eligibility rules, and in particular the ones that govern redshirt. Patterson argues that since redshirt players have five years to practice and graduate, there’s no persuasive reason to limit them to four seasons of D-I play. These players seek to expand their maximum number of D-I seasons from four to five. Patterson’s case is before the same judge, Campbell, who is weighing whether to grant a preliminary injunction to authorize a fifth season of play.

Pavia, 23, is a seasoned college football player. He’s playing in his sixth season of college football, with his first two seasons at JUCO New Mexico Military Institute and the last four at New Mexico State and Vanderbilt. Pavia is also one of the best quarterbacks in college football and recently finished second to Indiana’s Fernando Mendoza in the 2025 Heisman Trophy voting. Pavia is earning a great deal as a power conference QB, too. In June, he said he was offered $4-$4.5 million by other colleges to transfer.

Pavia has publicly indicated he intends to participate in the 2026 NFL draft. With more than two dozen other former JUCO players as co-plaintiffs, the case brought by Pavia against the NCAA could continue without him. The NFL’s deadline for underclassmen to declare is Jan. 14. If Pavia gains the choice to remain in college, it’s plausible he might stick around.

After all, Pavia’s NFL draft prospects are mixed. Listed at 6-foot and regarded as relatively slight, Pavia would be on the smaller side for an NFL quarterback. Although it is early for draft prognostications and the NFL combine isn’t until February, Pavia is generally regarded as a late-round draft pick or priority free agent. He also doesn’t project as a likely NFL starter, at least early in his NFL career. Those outlooks have financial implications. A sixth-round pick will sign a four-year contract worth in the ballpark of $4 million. With NIL and House settlement revenue share, Pavia could probably earn more, and potentially much more, by staying in college and dominating.

Last year at around this time, Campbell granted Pavia a preliminary injunction to play in 2025. Shortly thereafter, the NCAA issued a one-time waiver for the 2025–26 academic year that allowed qualified former JUCO players the chance to remain in school. Since that time, more than three dozen “Pavia lawsuits” have been filed by former JUCO and Division II players who want to keep playing in college. Also, in October, a three-judge panel on the U.S. Court of Appeals for the Sixth Circuit on Wednesday dismissed as moot the NCAA’s appeal of Campbell’s order on grounds that Pavia was already playing, and the NCAA had granted a waiver. The Sixth Circuit remanded the case back to Campbell.

In Friday’s court filing, Pavia describes this arrangement as unfair and unlawful under antitrust law. He notes how other categories of relatively older players receive five years of eligibility to play four seasons, a longer window than ex-JUCO players. Those categories include:

• A player who graduates from high school, then plays football at a prep school for a post-grad year before joining a D-I college.

• A player who plays another professional sport (Chris Weinke became a football player at Florida State in 1997 as a 25-year-old after a six-year pro baseball career).

• As of 2025, the NCAA allows former pro basketball players to play college basketball even though they are former pros in the G League and Europe. As noted by Pavia, former NBA draft pick James Nnaji, who grew up in Nigeria and has played professionally in Europe but not in an NBA regular season game, will soon join Baylor’s men’s basketball team. Sportico examined the topic of pro basketball players joining NCAA teams and its impact on Pavia v. NCAA in depth last summer.

Pavia insists that if the NCAA was worried about the impact that he and other seasoned college players have on competitive balance, “it would preclude other older athletes from competing in Division I NCAA sports.”

The antitrust argument leveled by Pavia depicts the NCAA and its member schools and conferences as engaging in a group boycott of former JUCO football players. By limiting how long these players can play D-I, those players are denied potential NIL and revenue-share compensation. Pavia’s expert witness, Dr. Joel Maxcy, is quoted as saying NCAA member schools enjoy a “financial advantage by moving older players out and replacing them with younger players,” since “an outgoing star would be considerably more costly to the school than an incoming player.”

The underlying logic is that football players of Pavia’s caliber, experience and fame can demand more in compensation from colleges than a teenage high school student who might not play a featured role in college until his sophomore or junior year. Pavia says by pushing “older, more experienced players” out of NCAA football, “schools will have the ability to bring in additional freshmen at a much lower cost.”

As Pavia tells it, D-I college football players constitute a labor market, meaning a group of players who seek to sell their (relatively) elite football services to colleges. Colleges, as competitors to buy players’ services, can run afoul of antitrust law by limiting how they compete.

To advance that point, Pavia draws extensively from former Ohio State football star Maurice Clarett’s antitrust litigation against the NFL. Clarett challenged an eligibility rule that requires players be three years out of high school. As a disclosure, I was one of the attorneys representing Clarett in the litigation. 

Clarett argued that the relevant market for his case was the market for NFL players, with NFL teams as the buyer of players’ services. That market is distinct and there are no reasonable substitutes; no one would credibly say the XFL, UFL, CFL, AAF or any other non-NFL pro league is a credible substitute. Pavia analogizes that point to say that the market for his services is D-I football, especially since “more than 99% of NIL dollars are paid to those athletes.” Neither playing in JUCO nor playing in the NFL is a substitute to D-I football, Pavia insists. He cites data showing how “less than 1% of Division I football players get drafted into the NFL each year.”

An NCAA spokesperson responded to a request for comment on Pavia’s latest court filing by providing context on the Nnaji eligibility decision. As discussed above, Pavia contends the NCAA allowing Nnaji and other former pro basketball players to play D-I undercuts the association’s justification to limit the number of eligible seasons.

“Each eligibility case is evaluated and decided individually based on the facts presented,” the spokesperson said in a statement. “Schools continue to recruit and enroll individuals with professional playing experience, which NCAA rules allow with parameters.”

The spokesperson added that “as NCAA eligibility rules continue to face repeated lawsuits with differing outcomes, these cases are likely to continue, which underscores the importance of our collaboration with Congress to enable the Association to enforce reasonable eligibility standards and preserve opportunities to compete for future high school student-athletes.”

Attorneys for the NCAA will have the opportunity to try to rebut Pavia’s arguments. 

Expect NCAA attorneys to argue, as they have in other court filings, that eligibility rules ought to fall outside the scope of antitrust law since they concern how long a college student can play a sport—a primarily educational, rather than economic, matter. 

The NCAA will also assert that eligibility rules are designed to link an athlete’s athletic experiences with the normal trajectory of a college student. Usually after four years of college courses, athletes and non-athlete students graduate and move on to another phase of life, usually a job.

In addition, the NCAA will likely maintain that Division I college football is a unique product and the closer it resembles an inferior version of the NFL, the more it will seem like minor league football. Fans, consumers, broadcasters, media and others, so the theory goes, could then tune out.



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Florida football transfer tracker as Jon Sumrall works the portal for 2026 class

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Updated Jan. 10, 2026, 9:46 p.m. ET



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Tennessee safety Boo Carter commits to Colorado out of NCAA transfer portal

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Tennessee safety Boo Carter has committed to Colorado out of the NCAA transfer portal, On3 has learned. Carter had a bit of a rocky relationship with the Volunteers, ultimately departing the program before the 2025 campaign had finished.

In two seasons at Tennessee, Carter recorded 63 tackles. He also notched two sacks, three forced fumbles, an interception and three passes defended.

Carter earned numerous SEC-related honors stemming from the 2024 season. He was a 2024 SEC All-Freshman team selection. He was also a 2025 preseason All-SEC third-team selection by the league’s coaches.

Boo Carter was arguably his most productive in terms of getting his hands on the ball in 2025. He logged 25 tackles, a sack, three forced fumbles and three passes defended this season.

But Carter didn’t stick around for the full season at Tennessee. He did not play in the team’s 42-9 win over New Mexico State in November. That absence was conspicuous.

Coach Josh Heupel expressed some disappointment in Boo Carter after the game. He shed a little light on the situation.

“At the end of the day, there’s a standard you’ve gotta meet to be in that locker room,” Heupel said. “So he was not out on the field with us. That will be my last response to anything related to that for right now.”

Boo Carter also missed several days with the team in July and went into call camp with questions about his availability. But he was able to work his way back into the good graces of the staff.

Ultimately, things didn’t end up working out at Tennessee. Shortly after that New Mexico State game, it was reported that Carter was splitting with the program.

“No, not regretful,” Heupel said. “At the end of the day, it’s our job as coaches to try to mold these guys, and that’s a part of the commitment that you make, you know, in the recruiting process and when they decide to come. You know, sometimes it works, sometimes it doesn’t. And, you know, at the end of the day, we’re moving forward.”

Prior to enrolling at Tennessee, Boo Carter was ranked as a four-star prospect and the No. 111 overall recruit in the nation, according to the Rivals Industry Rankings. He also checked in as the No. 3 athlete in the class and the No. 3 overall player from the state of Tennessee, hailing from Chattanooga (TN) Bradley Central.



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Is college football broken, or the best it’s ever been? Yes

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Indiana football is everything right now, representing at once the enhancement of the college football product on the field and the unsustainable reality off it.

No, Indiana didn’t do anything wrong — that we know of, anyway, though I’m sure other coaches would like to investigate Curt Cignetti and his players for spyware or cyborg blood or something. But as we wrap up a week that had the absolute best and worst of the sport clawing at each other for top billing, the Hoosiers should know they’ve made it so much harder for so many people.

Not that they should care. Go destroy Miami after people spend the week talking themselves back into why you can’t really be this good, then celebrate a national championship that would represent one of the most unforeseen, inexplicable, glorious stories in American sports history.

Indiana, even while making Friday night more boring than we wanted with a 56-22 semifinal thrashing of Oregon, is the prevailing example of why college football is in a great place as a product.

Never has there been more hope for so many. Membership in the exclusive club of heritage and built-in advantages is no longer required. A tallying of the recruiting stars next to names on a roster no longer produces a long and accurate list of programs with no shot of winning it all.

The landscape is always changing, never boring. Vanderbilt, Texas Tech, Ole Miss and Arizona State are among Indiana’s party-crashing undercards. The College Football Playoff is compelling. The games aren’t all thrillers, but enough of them are.

I would, though, like us to get through one of those good games without half of college sports media crowing on some app: “OH THAT’S WEIRD, I THOUGHT COLLEGE FOOTBALL WAS BROKEN.”

Because we all know darn well that, in ways, it is. Or maybe fractured sounds less dramatic. Chaotic. Problematic? Whatever makes you feel less bad. In the same week we’re enjoying the CFP semifinals, including an Ole Miss-Miami classic, we’ve got the former coach of Ole Miss keeping assistant coaches from attending the ball like he’s Cinderella’s stepmother.

We’ve got that same coach, LSU’s Lane Kiffin, courting one quarterback (Arizona State transfer Sam Leavitt) at a basketball game while another (Washington’s Demond Williams Jr.) announces he’s in the portal, apparently with the idea of joining Kiffin, except he had already signed to stay on with Washington. Except we have contracts in college sports that seek to sort of bind, while being careful not to make the person being paid sound as if he or she is being paid to play. Even though that’s exactly what’s happening.

So it’s the latest but far from the last “contract dispute,” this one finishing with Williams deciding to return to Washington. And hey, look, here comes the College Sports Commission promising to start cracking down on these predictable workarounds to pay enough to land top players in a market that is rising.

Which, at best, means an example made of a program or two, and in no way means any chance for the CSC to get its arms around things. Men and women with gavels and long, black robes will continue seeing to that. Lawmakers aren’t changing it.

Collective bargaining, in some form, is the only answer, and more and more people in the industry are coming around on that. The painful, inevitable journey continues. Hopefully, the past week serves as a bit of a jolt. I talked to an administrator who has been in that camp for a while and believes the athletic director and president levels are getting there.

But that will have unintended consequences, too. Go back and read what a lot of us were writing about name, image and likeness rights 10 or 15 years ago. I don’t recall anyone coming close to predicting all that has come with it.

And I must wonder how, with a cap of some sort in place while athletes get a bigger chunk of the revenue overall, the boosters at Ohio State, Alabama and Georgia are going to feel about officially being like everyone else, about parity as league design — about the caddies getting full-time access to the pool and golf course.

Which brings us to the thing I hear the most from folks in college sports in terms of long-term concerns. And this is where Indiana re-enters the discussion, in three words: return on investment. Indiana AD Scott Dolson has made what must be considered, two years later, one of the great hires in modern college football history. As hyperbolic as that may sound.

And for as much as this should be seen as an outlier that will spawn books and documentaries, it only serves to intensify the pressure elsewhere. All your resources, all that time, and you couldn’t figure this out, Penn State? Steve Sarkisian and Arch Manning can’t match this James Madison dude and Fernando Mendoza? Wasn’t USC the program with the great quarterback developer and offensive designer?

Those programs are at least having some success. All of them are begging the millionaires and billionaires who have helped build a facility or throw some nice cars at recruits of the past to sustain competitive payrolls. The TV money is good, but check the expenses. Colleague Seth Emerson wrote about “donor fatigue” in 2024 and, spoiler alert: No one has gotten any rest.

The wealthy folks who pay NFL players are called owners, and their investments are being multiplied many times over. The wealthy folks who pay college players get names on buildings, seats on the team plane and games of catch between the star quarterback and their grandkids. NFL owners lose, fire people, draft high and continue to profit; college boosters increasingly feel like they’re setting large piles of money on fire.

Which is why private equity looks as inevitable as collective bargaining. This is more than just a slight hairline fracture that will heal on its own.

I hope you can enjoy the college football right now. The product is soaring. Also, I hope anyone who cares about it understands that it can plummet without improved leadership that values common sense, the greater good of the industry and all of its employees.

If you’re an Indiana fan, soak in these experiences that are Cignetti-driven but still possible only because of NIL and the transfer portal. And plan to stay for a while. Cignetti never looks like he’s satisfied, and Mark Cuban is looking awfully happy right now.





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What if Not NIL but Hit the Road Jack

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I for sure have been concerned about all the players abandoning the ship, but what if they were talked to about not doing their jobs. What if they were given the option of either putting in the work or finding a new home. Could we have been wrong in some cases thinking the player was looking for more $ rather than putting the work in. Some players, as you know, don’t live up to their billing. OSU is one of the premier colleges for education and sports. I think when the players were recruited out of HS, they jumped at the chance to be a Buckeye. Now, the players see how difficult it is to live up to the expectations that is required to be a Buckeye. This is just a different take on what we have witnessed so far with the transfer portal. I what to find out how 11W members feel about this.



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Sports broadcasting’s parroting problem is bordering on the shameful

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OK, time’s up. After 30 or so years, it’s time to end the Idiots’ Picnic, time to go home, time to remove the rehearsed-then-parroted nonsense from sports telecasts. 

First one that must go is transfer portal. That’s a crock. Those are, in fact, mostly NIL price-tagged signings of college athletes without academic credentials. They are free agents, too many without the ability to read or write functional English. 

In 2012, Ohio State QB Cardale Jones presaged the NIL scene when he tweeted, “Why should we have to go to class if we came here to play FOOTBALL, we ain’t come to play SCHOOL, classes are POINTLESS.” 

That sad, shameful and nationally ridiculed message is now the daily reality! 



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CFP overreactions: Miami discipline issues will prove costly vs. Indiana

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And then there were two. The 2026 college football season has led to this: No. 1 Indiana and No. 10 Miami will meet in the College Football Playoff National Championship Game to decide the best team in the country. 

In most years, the Hurricanes would be seen as an overwhelming favorite against Indiana. But Miami has gone on an underdog run of its own after making the playoff as the last at-large team. 

Indiana, meanwhile, has bowled over opposing teams en route to a 15-0 record. The Hoosiers are 2025’s hegemon and it appears as if they aren’t going away anytime soon. 

They handled their semifinal game against Oregon with ease, downing the Ducks 56-22. Miami, meanwhile, triumphed over Ole Miss in a 31-27 thriller that ranks as one of the best postseason games of the CFP era

Those semifinal games, of course, provided plenty of material to overreact to as the 2025 season nears its conclusion. 

Indiana is the best team of the CFP era 

Yes, better than 2019 LSU. The Hoosiers may not have as much elite NFL talent — though quarterback Fernando Mendoza is a shoe-in to go first overall in the 2026 draft — and the offense isn’t quite as explosive, but they are a more complete team. 

Indiana’s +473 point differential ranks first among schools in the playoff era (hat tip to my CBS Sports colleague Tom Fornelli). The Hoosiers have bludgeoned opposing teams by an average of 31.5 points per contest. Their last three wins against blue bloods Ohio State and Alabama and new blood Oregon have come by a combined score of 107-35. 

Curt Cignetti’s squad has won all but one of its games against ranked opponents by at least 10 points. And Indiana is doing this in the Big Ten, one of the nation’s premier conferences.  

The Hoosiers are also on the precipice of becoming the first college football program to ever go 16-0. Of course, they have the benefit of playing in the expanded playoff years, but an undefeated season in the modern era of college football, when parity is at an all-time high thanks to NIL, seems like an accomplishment that won’t be easily repeated. 

After all, only four NFL teams have ever completed undefeated seasons and it only happened once after the league went to a 16-game schedule. 

Indiana vs. Miami: Early preview, odds, picks as Hoosiers will meet Hurricanes in CFP National Championship

Chip Patterson

Indiana vs. Miami: Early preview, odds, picks as Hoosiers will meet Hurricanes in CFP National Championship

Miami’s discipline issues will doom it against Indiana

Miami was, somehow, able to overcome itself in the Fiesta Bowl against Ole Miss. The Hurricanes committed 10 penalties for a total of 74 yards, including a targeting foul that resulted in the ejection of cornerback Xavier Lucas. They dropped four potential interceptions. 

Those fouls allowed Ole Miss to hang around and even take the lead at certain points. Ultimately, the Rebels made a few crucial mistakes of their own — and were pitiful on third down — which allowed the Hurricanes to outlast Ole Miss. 

That won’t do against the well-oiled Indiana machine. The Hoosiers rank third nationally with just 3.57 penalties per game. They’re smart, they’re disciplined and — as was seen with D’Angelo Ponds’ pick six to open Indiana’s semifinal win over Oregon — they will pounce all over any mistakes the opponent makes. 

Ultimately, discipline will make the difference in a battle between two teams that stack up fairly well otherwise. 

Oregon is in trouble 

You’ve certainly heard of a clutch gene if you’re a fan of sports. Oregon coach Dan Lanning has the opposite. 

In their last three playoff games against Power Four opponents, the Ducks have been outscored 97-66. That includes a 23-0 romp against Big 12 champion Texas Tech this season. 

Talent isn’t the issue with Oregon. The Phil Knight money certainly helps, but the Ducks have always recruited at a high clip. Coach Dan Lanning has done a good job at the high school level and in the portal. 

But there’s plenty of reason to be concerned about the path that Oregon is walking with Lanning, especially given the recent postseason results. This will be a big offseason for him. 

The Ducks are set to lose both of their bright young coordinators. Will Stein is headed to coach Kentucky while Tosh Lupoi will lead former Pac-12 foe California. 

It is a good sign for a program’s health when assistants get head coaching jobs, and it’s a testament to what Lanning has built at the young age of 39. The next few months will be a huge test of his ability to keep the ship steady. 

Ole Miss is bigger than Lane Kiffin

It was time to stop talking about Kiffin’s move to LSU once the playoff began, but the two will always be intrinsically linked given the time that Kiffin had in Oxford and the messy nature in which he departed. While Kiffin deserves his flowers for elevating the standard at Ole Miss, it’s clear that the Rebels have outgrown the need for him. 

His departure didn’t do the program any favors or anything like that. Pete Golding has shown, in short order, that he can at least maintain the level of success that Kiffin established — if not exceed it. Golding, after all, has more playoff wins than Kiffin at this point, and he’s only been a head coach for three games. 

Kiffin was certainly hoping that he’d be able to drag some of Ole Miss’ top stars with him, but his decision instead galvanized the Rebels. Top running back Kewan Lacy, top linebacker Suntarine Perkins and edge rusher Princewill Umanmielen, along with a bevy of other key players, have already committed to returning. 

On top of that, Ole Miss is off to an incredible start in the transfer portal. The Rebels currently sit seventh in 247Sports’ Team Transfer Rankings. They’re one of just two schools in the top 10 with less than 10 commits thus far and their average prospect grade of 89.22 is first among top-15 transfer classes. 

Four of Ole Miss’ nine transfer additions hold at least a four-star ranking. That includes LSU transfer Carius Curne, the No. 1 offensive tackle in the transfer portal, who spurned Kiffin for the Rebels. 





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