NIL
Key legal developments in college athletics
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.
NIL
College Football Playoff team loses two-time All-American to transfer portal
Tulane finished the regular season as American Athletic Conference champion and secured the AAC’s automatic berth into the expanded 12-team College Football Playoff, closing the year with a 12–1 record.
Unfortunately, the Green Wave’s historic season ended with a 41–10 loss to Ole Miss in the first round, as the Rebels dominated from the opening kickoff and advanced to face No. 3 Georgia in the Allstate Sugar Bowl.
Jon Sumrall, Tulane’s head coach since December 2023, guided the program to consecutive conference-title contention and the 2025 AAC crown before taking the open Florida job on November 30, agreeing to a six-year deal worth nearly $7.5 million annually.
Now, one of the Green Wave’s cornerstone players is set to leave alongside him.
On Wednesday, Rivals’ Hayes Fawcett reported that Tulane All-American interior offensive lineman Shadre Hurst is entering the NCAA transfer portal.
Hurst is a redshirt junior interior lineman who has started 36 career games for the Green Wave, earning First-Team All-AAC honors and All-American recognition in both 2024 and 2025.
Tulane’s athletic department also placed Hurst on multiple preseason national watch lists in 2025, including the Outland Trophy Preseason Watch List.
Pro Football Focus graded Hurst with a 90.5 pass-blocking mark, placing him among the nation’s highest-rated pass protectors at his position.

Before arriving at Tulane, Hurst was a Cartersville (Georgia) high-school product who earned First Team All-State honors from the AJC and First Team All-Region 7-AAAAA recognition.
He also emerged as one of the Southeast’s top heavyweight wrestlers, finishing state runner-up as a junior before winning a state championship as a senior.
Despite those accolades, Hurst was an unranked prospect who held just five offers—Tulane, UMass, Washington State, Chattanooga, and Southeast Missouri State.
Now, he is widely viewed as both an NFL prospect (projected third- to fourth-round pick) and a highly attractive Power Four transfer target in need of experienced interior offensive line help.
Read More at College Football HQ
- $1.6 million QB linked to College Football Playoff program
- SEC head coach named as ‘surprising’ candidate to replace Sherrone Moore at Michigan
- Unexpected college football program among favorites for $2 million transfer QB
- Major college football QB expected to ‘command’ up to $5 million in transfer portal
NIL
Ole Miss Reportedly Offers Historic NIL Package to Bring Back Elite Offensive Weapon
Ole Miss Rebels running back Kewan Lacy is in the midst of a historic 2025 season after joining the program in Oxford last offseason.
The Missouri Tigers transfer has taken on a significant workload for the Rebels where his meteoric rise catapulted his status to a Doak Award finalist – annually given to America’s top running back.
Lacy was named a first team All-American by the Football Writers Association of America last week after a historic 2025 campaign.
It became the sixth All-America honor for Lacy, who was also the first Doak Walker Award finalist in Ole Miss history.
Lacy has been a second-team honoree on other All-America teams released by the Associated Press, AFCA, The Sporting News, Walter Camp and Sports Info Solutions. Lacy has also been a first-team All-SEC running back for both the AP and the league coaches.

The Ole Miss star running back has been one of the best rushers in the nation all season long for the 12-1 Rebels, currently holding a season line of 258 attempts for 1,279 yards and 21 touchdowns.
But there remains buzz surrounding Lacy’s future in Oxford amid Lane Kiffin’s move from Ole Miss to LSU this fall.
Once Kiffin accepted the LSU Tigers head coaching job, the rumor mill started swirling surrounding where he would play during the 2026 season: Could Ole Miss retain him or would he enter the portal?
Fast forward to Monday and Ole Miss running backs coach Kevin Smith was formally introduced as the next running backs coach/associate head coach of the LSU Tigers – joining offensive coordinator Charlie Weis Jr. and others in Baton Rouge.
Now, with Lacy’s former head coach, offensive coordinator, and position coach on staff with the LSU program, there is concern surrounding his future in Oxford.

But the Ole Miss Rebels aren’t going down without a fight, according to multiple reports, with the program offering a significant NIL package in hopes of having him back for the 2026 season.
According to LouisianaSports.net, the Ole Miss Rebels are offering a $1.8 million deal to get him back next fall:
“Lacy has not declared his intention to enter the portal, however, a video surfaced of a phone conversation where Kiffin suggested Smith and Lacy would be joining him at LSU.
“LouisianaSports.net previously reported Ole Miss has offered Lacy $1.8 million to return to the Rebels in 2026.”
Now, as Lacy’s future with Ole Miss remains in questions, it’s no secret that Rebels officials are rolling out the red carpet in hopes of having him back with the program for next season with a strong offer presented.
More Ole Miss News:
Lane Kiffin Reacts to New Offensive Coordinator Being Hired By Ole Miss Football
Ole Miss Football QB Trinidad Chambliss Wins Major Award Amid Breakout Season
ESPN Predicts Outcome of Ole Miss Football vs. Tulane Green Wave in CFP Showdown
Join the Community:
Follow Zack Nagy on Twitter: @znagy20 and Ole Miss Rebels On SI: @OleMissOnSI for all coverage surrounding the Ole Miss program.
NIL
Surprising List Of USC Trojans’ Biggest NIL Valuations
The USC Trojans have one of the bigger NIL funds in the entire country. Here are the Trojans’ top five highest NIL valuations according to On3.
1. Jayden Maiava, Quarterback ($2.1 million)

It’s common for the quarterback to be the most valued player on a team, so Maiava being where he is makes sense. Maiava just wrapped up his third collegiate season and first as the full time starter for coach Lincoln Riley and the Trojans.
Maiava threw for 3,431 yards, 23 touchdowns, and eight interceptions in the regular season. He added another 150 yards and six touchdowns on the ground. With Maiava taking this far of a step forward, it was interesting to see if he would decide to return to USC for another year or declare for the NFL Draft.
Maiava ended up re-signing with the Trojans, bringing back the engine of the USC offense for 2026.
2. Makai Lemon, Wide Receiver ($1.1 million)
Makai Lemon is coming off an incredible 2025 season in which he won the Biletnikoff Award for being the best wide receiver in college football. Lemon was top ten in the country in receiving yards with 1,156, receptions with 79, and receiving touchdowns with 11. Lemon declared for the 2026 NFL Draft.
3. Husan Longstreet, Quarterback ($753 thousand)

Husan Longstreet was the highest rated USC recruit in the class of 2025. He didn’t see much of the field as a true freshman as he was the backup to Maiava, but the hopes are high for Longstreet’s future with the Trojans once Maiava does leave.
In his limited action on the field in 2025, Longstreet threw for 103 yards, one touchdown, and zero interceptions while rushing for 76 yards and two touchdowns.
MORE: USC Trojans Battling Recruiting Powerhouses for Five-Star Safety
MORE: What Ethan “Boobie” Feaster’s State Championship Heroics Mean For USC Recruiting
MORE: What USC’s Betting Odds vs. TCU Says About Trojans Amid Opt Outs
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4. Bishop Fitzgerald, Safety ($552 thousand)

Bishop Fitzgerald transferred from NC State to USC prior to the 2025 season. Fitzgerald was a good edition, and recorded 51 total tackles, five interceptions, three passes defended, one sack, and a touchdown. He was named an All-American for his play.
5. Devan Thompkins, Defensive Lineman ($508 thousand)
Devan Thompkins finished his third season with the Trojans in 2025. He had 56 total tackles, 4.5 sacks, five passes defended, and one forced fumble. The Trojans will be without Thompkins next season as he entered his name in the transfer portal.
Trojans Prepare For Alamo Bowl

The 2025 USC Trojans still have one more game this season before they will fully move on to 2026. They will take on the TCU Horned Frogs on Dec. 30 in the Alamo Bowl. According to DraftKings Sportsbook, USC is a 6.5-point favorite.
A win would result in a 10-3 finish, the best season for the program since 2022.
- Game odds refresh periodically and are subject to change.
- If you or someone you know has a gambling problem and wants help, call 1-800-GAMBLER.
NIL
College football program loses 22 players to transfer portal
The NCAA transfer portal will open for all college football players looking for a new school to play for in the 2026 season.
The transfer portal can be an exciting prospect for successful programs looking to reload their talent pool ahead of the following season. For struggling programs, the idea of roster retention can feel like an uphill battle against potential suitors in the transfer portal.
One program that is fighting the aforementioned uphill battle with roster retention is West Virginia. A multitude of players on the 2025 roster for the Mountaineers have already decided to look for greener grass in the transfer portal.

Among the more notable departures for the Mountaineers in the 2026 offseason will be quarterback Khalil Wilkins and running backs Jahiem White and Diore Hubbard.
Wilkins was given snaps as a backup in games against Robert Morris, Kansas, Utah, BYU, UCF and Texas Tech. He tallied 185 passing yards, a touchdown pass and two interceptions while rushing for another 243 yards and two interceptions.
While his 2025 season was far less productive due to injury, White had been given a lot of run with the Mountaineers in his prior two seasons in the program. He accumulated 1,820 yards and 14 touchdowns on the ground while catching 27 passes for 262 yards and three touchdowns in three seasons.
Hubbard finished 2025 as West Virginia’s most productive running back. He ran for 335 yards and four touchdowns and caught 16 passes for 156 yards.

So far, 247Sports has reported 19 other players will transfer out of West Virginia.
Offensively, running backs Tyler Jacklich, Kannon Katzer and Clay Ash, wide receivers Tyshawn Dues and Oran Singleton Jr, and offensive linemen Robby Martin, Cooper Young, Jude Edwards and Ethan Chill are heading for the portal.
On defense, linemen Adam Tomczyk and Jackson Biser, linebacker Mike Hastie, and defensive backs Zae Jennings, William Davis, Dawayne Galloway Jr., Devonte Golden-Nelson, Kaleb Gray, and Matthias Squire are all exiting. Punter Aidan Stire is also entering the transfer portal.
The Mountaineers rehired Rich Rodriguez to be their head coach after parting with Neal Brown at the conclusion of the 2024 season. Rodriguez coached at West Virginia from 2001-2007 and had held head coaching jobs at Michigan, Arizona and Jacksonville State after leaving.
West Virginia finished 14th in the Big 12 standings with its 4-8 overall record. The Mountaineers’ 2025 wins were against Robert Morris (45-3), Pittsburgh (31-24), Houston (45-35) and Colorado (29-22).
NIL
Miami NIL financial commitment in 2026
The landscape is evolving fast, and more teams saw the success of Miami, Texas Tech, Oregon, and Indiana in the portal, and will become more
competitive. Texas Tech is doubling down, and we can expect more competition even inside the ACC with Clemson and VaTech. Point here, is what was good and competitive in 2025, wont be enough in 2026. Solid HS recruiting helps, but just look at the impact of our portal class this season. January 2nd through the 10th is going to be crucial, and hope we have our ducks in a row right now. The financial commitment needs to grow to be on par with Texas Tech and Oregon.
NIL
College football: Four key Gophers coming back in unique NIL campaign
PHOENIX — Four important Gopher football players were part of a unique media campaign on Tuesday.
Offensive linemen Greg Johnson and Nathan Roy, and defensive backs John Nestor and Kerry Brown allowed the Gophers’ NIL collective, Dinkytown Athletes, to share news they will play in the Rate Bowl against New Mexico on Friday, and will return to Minnesota for the 2026 season.
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The social media posts were “presented by Cub Foods,” and those players will be recipients of the grocer’s NIL contribution next year. Dinkytown Athletes serves as a subcontractor.
Athletics Director Mark Coyle called Cub Foods a “foundational partner” of Gopher sports.
“That is how we take the next step, with that type of involvement with NIL side of it,” Coyle told the Pioneer Press. “We are so grateful for their support.”
A few more current Gopher players are expected to join the Cub Foods campaign after the bowl game. But if players on the current roster aren’t included in this specific rollout, that doesn’t necessarily mean they are leaving the U to go into the transfer portal.
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For instance, quarterback Drake Lindsey said, independently, two weeks ago that he would return to Minnesota for his redshirt sophomore season in 2026. Other current players have shared they will be back with the Gophers next year.
Meanwhile, the futures of defensive end Anthony Smith, safety Koi Perich and running back Darius Taylor have yet to be shared. Smith and Taylor said Wednesday they have not yet made decisions on their plans for 2026; both are in line to play in the bowl game at Chase Field.
“I really haven’t thought about that stuff,” Taylor said. “I’m just worried about the game. I will figure all that out after the game.”
Smith said he hasn’t ruled out entering the transfer portal. “I don’t know,” he said.
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Johnson, who started all 12 regular-season games at guard, will return for his senior season next fall. The Prior Lake native played nearly 700 snaps and was Minnesota’s highest-graded starting offensive lineman in 2025 (75.3 overall mark, per Pro Football Focus).
“Being from Minnesota, I personally didn’t have any thoughts of going elsewhere,” Johnson said. “I think Drake really set the tone for the team. This is Drake’s team. He’s our leader and it’s easy to come back and want to play for a guy like that.”
Roy stepped in as the U’s left tackle during his redshirt freshman year with aplomb, playing a team-high 702 snaps with a 69.0 grade from PFF. The Mukwanago, Wis., native will be back for his redshirt sophomore year.
Nestor transferred in from the Iowa Hawkeyes last year, and the Chicago native started 10 of 12 games as Minnesota’s most-reliable corner. He had a team-high five interceptions, adding 47 tackles in 538 total snaps. He will be a senior in 2026.
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Brown continued as a linchpin in Minnesota’s defense for second straight season. The safety and nickel back from Naples, Fla., was fourth on team with 55 tackles and added two interceptions in 579 snaps. He will return for his redshirt junior year.
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