NIL
NCAA Fights Zakai Zeigler’s Antitrust Suit, Defends Four-Seasons Rule
The NCAA on Monday motioned a federal judge to deny Zakai Zeigler’s motion for an injunction in his antitrust lawsuit to keep playing playing Division I basketball as a college graduate who already played four D-1 seasons. The NCAA’s motion sends a warning that Zeigler’s lawsuit could open the door to numerous players staying on teams for years after they graduate—and taking spots away from incoming freshmen.
Zeigler, 22, graduated from the University of Tennessee last month. The 5-foot-9 native of Long Island, N.Y. is a two-time SEC Defensive Player of the Year and set several team records. He played all four seasons at Tennessee, where he also received recognition for academic achievement.
Zeigler would like to play a fifth season as a graduate student, but the NCAA only allows four seasons of intercollegiate competition within a five-year window. Zeigler contends the four-seasons rule violates antitrust law by depriving him and similarly situated players of athletic skill development and NIL opportunities—Zeigler contends he’d earn as much as $4 million in NIL in 2025-26 since he’s a well-known and successful college player from a prominent program. He argues there’s a less restrictive approach where the NCAA could allow for an additional season if a player completed their undergraduate degree in four years, meaning they did not red shirt and their academic advancement followed the typical path for college students.
The NCAA repudiates Zeigler’s arguments in a brief authored by Taylor J. Askew and Rakesh Kilaru and colleagues from Holland & Knight and Wilkinson Stekloff. Among the points raised in the NCAA’s brief is that Zeigler is not an NBA prospect and thus an additional season is unlikely to make him a candidate for the NBA. “All publicly available evidence indicates that Plaintiff, respectfully, has a difficult path to the NBA, at this juncture,” the brief states.
The brief acknowledges that Zeigler is a terrific college player—he’s the all-time leading scorer and assist leader in Tennessee history—but pivots from that point to assert, “presumably, if [Zeigler] had a viable path to the NBA, given his resume, he would already be a viable prospect. After all, NBA scouts would have seen him play in 138 collegiate contests.” The brief also bluntly mentions, “there is no proof in the record that Plaintiff was even invited to either the NBA Combine or G-League Combine this year.”
Similarly, the NCAA highlights how “there is no evidence that one more season of participation in college basketball is necessary” for Zeigler to play pro hoops. To that point, Zeigler could have tried to join the NBA, G League or a foreign league years ago. He met their minimum age and experience requirements but chose to remain in college and advance toward a degree.
Zeigler is also depicted as selfish. As the NCAA spins it, Zeigler is asking a court to make him the first college athlete “in history” to obtain a judicial decree to play a fifth season “as a matter of right.” If Zeigler is granted that chance, there would be a loser: a roster spot for a graduating high school senior would otherwise join the Volunteers would be “reapportioned” to Zeigler.
In fact, the NCAA estimates that if college seniors who played four seasons could play another season and chose to do so, somewhere between 20% and 25% of roster spots that would have gone to incoming freshmen would be lost. “While Plaintiff focuses only on what that means for himself,” the NCAA writes, “he does so to the detriment of the entering student-athletes who dream of being the next Zakai Zeigler.”
In that same spirit, the NCAA defends the four seasons rule as reflecting “the lifecycle of a collegiate athlete.” Stated differently, NCAA sports are intended to be a career. A college student plays a sport and their college athletic career time ordinarily ends when they graduate. This “lifecycle,” the NCAA argues, ensures a “steady stream of opportunities” for graduating high school players to gain a college education and play sports.
“College athletics,” the NCAA asserts, “is a means to a better end for student-athletes—not the end itself.”
The NCAA also maintains that Zeigler, like other athletes who have sued the NCAA in recent months to extend their eligibility, has “misapprehended” the U.S. Supreme Court’s decision in NCAA v. Alston (2021) for legal principles that the Court rejected.
Although Alston is sometimes linked to NIL, the case had nothing to do with NIL. The NCAA stresses that Alston only addressed compensation rules for athletes’ education-related expenses, which are subject to antitrust scrutiny since they involve commercial activity. However, Alston does “not touch” eligibility rules, which the NCAA asserts fall outside the scope of antitrust scrutiny. As the NCAA tells it, eligibility rules are not about commercial transactions and instead concern who counts as a college athlete—a “necessary” ingredient “to create the product of collegiate sports.” Even Justice Brett Kavanaugh’s oft-cited concurring opinion, in which lambasted the NCAA and amateurism, explicitly stated that Alston “involves only a narrow subset of the NCAA’s compensation rules.”
The NCAA further asserts that relevant precedent in the U.S. Court of Appeals for the Sixth Circuit, which governs the Tennessee federal court where Zeigler sued, also instructs that eligibility rules fall outside the scope of antitrust scrutiny. As the NCAA recently cited in an appellate brief in Vanderbilt quarterback Diego Pavia’s case against the NCAA regarding eligibility rules, the Sixth Circuit held in Claude Bassett v. NCAA (2008) that enforcement of NCAA rules “is not within the purview of antitrust law” since those rules are not related to commercial or business activities.
Another alleged defect in Zeigler’s lawsuit is that it has “no limiting principle,” meaning if a player has a legal right to play a fifth season so they can earn more NIL and further refine athletic skills, the same player could raise the same argument for a sixth season and so on. Universities have no shortage of graduate programs in which an athlete could remain enrolled for, at least in theory, many years.
The NCAA also contends that a core premise of Zeigler’s lawsuit, which argues that removing experienced college players harms the labor market, is erroneous. While Zeigler suggests NIL deals are most lucrative for seniors, the NCAA says “non-seniors, on average, have higher NIL valuations than seniors.” The NCAA’s expert witness, Cal Berkeley economics professor Matthew Backus, provided a declaration referencing that individual NIL valuations for college basketball players shows that non-seniors’ have a higher average NIL valuation than seniors, $1.2 million compared to $1.07 million.
The issuance of a preliminary injunction for Zeigler, the NCAA argues, is also misplaced because any harm he suffers from not playing can be quantified. A core element to a preliminary injunction is that denial of one by a judge would likely cause the plaintiff irreparable harm, meaning a harm that money damages can’t remedy.
The NCAA maintains there are several problems with Zeigler claiming irreparable harm. One is that he “has known since his first day on campus that he had five years to complete four seasons” and yet waited until after he graduated college to sue. The NCAA believes that Zeigler manufactured an emergency when in reality, he could have sued years ago, giving the court time to review the case’s merits.
Also, the NCAA asserts, any injury Zeigler suffers by a denial to keep playing would be calculable.
The NCAA notes that Zeigler didn’t enter the transfer portal, “unlike 100+ other collegiate basketball players who have exhausted their eligibility but are either contemplating suing for more or hoping for an NCAA rule change.” If Zeigler plays another season, “he will assuredly play for the University of Tennessee,” the NCAA points out. Zeigler submitted a supporting exhibit of data from Spyre Sports Group, which has an NIL collective for Tennessee athletics and estimates Zeigler’s NIL value in another season would be worth $2 million to $4 million. That is important, the NCAA maintains, because it shows Zeigler’s potential legal injury could be resolved by monetary damages if he eventually wins a trial.
U.S. District Judge Katherine A. Crytzer will hold a hearing on Zeigler’s motion for a preliminary injunction on Friday at 1:45 pm local time in a Knoxville (Tenn.) federal courthouse.
Kentucky Basketball suffered a notable recruiting setback this week as 247 Sports national analyst Travis Branham removed his crystal ball prediction for the Wildcats to land class of 2026 5-star power forward Christian Collins. Branham originally placed the prediction in early November, fueling optimism that Collins could commit to Kentucky as the early national signing period approached. That announcement never came, and momentum has since cooled.
Collins, a 6-foot-8, 200-pound forward from Bellflower, California, is widely regarded as one of the premier frontcourt prospects in the country. His blend of athleticism, scoring ability, and defensive versatility made him a major priority for Kentucky head coach Mark Pope and his staff as they work to build future recruiting classes.
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According to Jacob Polacheck of KSR, Collins’ recruitment is being heavily influenced by NIL structure and contract details, a growing trend at the top of the recruiting landscape. That reality was addressed publicly earlier this month by Kentucky athletic director Mitch Barnhart during Will Stein’s introductory press conference as the Wildcats’ new football head coach.
Barnhart pushed back strongly against the perception that Kentucky is at an NIL disadvantage, saying, “Enough about ‘have we got enough?’ We’ve got enough.” He also emphasized that Kentucky will not compromise its standards to land recruits. “We’ve got to do it the right way,” Barnhart said. “We’re not going to break the rules. That’s flat-out.”
While Kentucky no longer holds a crystal ball prediction for Collins, the Wildcats are not out of the race. However, his recruitment now appears far more fluid, underscoring the increasingly complex balance between elite talent, NIL expectations, and long-term program philosophy in modern college basketball.
Less than two months after announcing his intention to run for lieutenant governor in Alabama, former three-time national champion Crimson Tide quarterback AJ McCarron has announced he will exit the race.
McCarron is seeking to rededicate himself to football, an effort that will require “100% of my focus, commitment, and attention that I was to give to the office of lieutenant governor, so it is time to end my campaign,” he said in a statement.
A historic career at Alabama
McCarron led the Crimson Tide to back-to-back BCS national championships in 2011 and 2012 and was part of the national title team as a redshirt player in 2009.
A native of Mobile, the quarterback became the first player at his position to win consecutive BCS titles and also received several of college football’s more prestigious awards, including the Maxwell, Johnny Unitas Golden Arm, and Kellen Moore Awards.
As a junior, McCarron established an Alabama record with 30 touchdown passes in a season, and broke Greg McElroy’s former record with 3,063 passing yards in a season during his senior campaign in 2013.
McCarron finished his Alabama career with a 36-4 overall record, completing almost 67 percent of his passes with 77 touchdowns and 15 interceptions.
McCarron in the NFL
The quarterback emerged as a fifth-round selection in the 2014 NFL Draft by the Cincinnati Bengals, playing as a backup for four years.
McCarron spent the next four seasons as a reserve first with the Oakland Raiders, followed by a stint with the Houston Texas, and finally the Atlanta Falcons.
From there, he played in the XFL with the St. Louis Battlehawks, a franchise that then moved to the United Football League.
McCarron’s political ambitions
The former quarterback star was running as a Republican for the second-highest office in his home state, a move he said was inspired by the murder of conservative political activist Charlie Kirk.
“Alabama’s conservative and cultural values are under attack from every direction,” McCarron said in his announcement for office.
“That’s why Charlie Kirk’s assassination affected so many of us so deeply. His example convinced me to get off of the sidelines, get into the game, and stand tall for our conservative beliefs.”
McCarron currently serves as a college football commentator as part of The Dynasty podcast, which he presents with fellow Alabama alum Trent Richardson and Crimson Tide broadcaster Chris Stewart.
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Dec. 17, 2025, 1:41 p.m. ET
USC will get its starting signal-caller back in 2026.
On Tuesday, the program announced that quarterback Jayden Maiava has signed a new NIL deal to return to the Trojans next season. Maiava, who previously played at UNLV, would have had a significant transfer portal market and also ranked as a top-10 quarterback prospect in the 2026 NFL draft, per ESPN’s Mel Kiper.
Maiava started 11 games at UNLV in 2023 before transferring to USC, where he ultimately lost the starting job to Miller Moss ahead of the 2024 season. However, amid subpar play from Moss, coach Lincoln Riley made a change as he started the final four games.
Though his numbers during that stretch weren’t stellar, he did guide the Trojans to a 3-1 finish to the season.
Riley opted not to take a transfer quarterback this offseason and stuck with Maiava, who started all 12 games in a 9-3 season. He took a major leap, completing 66.2% of his passes for 3,431 yards, 23 touchdowns and eight interceptions.
Maiava also ran for six touchdowns this fall.
He became one of the Big Ten’s top quarterbacks this season, and for the first time since Riley’s second year at USC with Caleb Williams, the Trojans will have a proven, incumbent starting quarterback back in 2026.
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Created to fully-fund revenue share and to grow endorsement opportunities for Oklahoma State student-athletes, The Alliance pairs the POSSE Excellence Fund with Learfield’s Cowboy Sports Properties.
The POSSE Excellence Fund provides more than $31 million in scholarships and revenue share for student-athletes across all of OSU’s ticketed sports. Cowboy Sports Properties integrates NIL opportunities for student-athletes into OSU’s existing sponsorship, media and marketing ecosystem.
“The OSU NIL Alliance will streamline how our supporters can maximize new opportunities for our student-athletes and continue to position OSU for championship-level success.” Athletic Director Chad Weiberg said.
Weiberg appointed Brakston Brock to lead this next step in OSU’s NIL evolution. Brock has climbed the ranks during his six years in Stillwater and now elevates into the role of Senior Associate Athletic Director for NIL Strategy and Revenue Generation.
For more information on the OSU NIL Alliance, visit https://okstate.com/nil.
If Bailey and Rodriguez receive first-team honors Thursday from the final selector, the Football Writers Association of America (FWAA), they would join Mark Bounds (1991), Zach Thomas (1995), Byron Hanspard (1996), Michael Crabtree (2007–08), and Jace Amaro (2013) as Texas Tech’s all-time unanimous All-America selections.
Bailey, an edge rusher, and Rodriguez, a linebacker, were previously named first-team All-Americans by the Walter Camp Football Foundation on Friday, the Associated Press on Monday, and the AFCA on Tuesday. The NCAA will officially recognize its consensus All-America selections on Friday.
Before the 2025 season, 27 Texas Tech players had earned first-team All-America honors, accounting for 49 all-time All-America selections (first-, second-, or third-team). In addition to Bailey and Rodriguez’s first-team recognition, the Associated Press named A.J. Holmes Jr. to its second team and defensive tackle Lee Hunter to its third team on Monday, marking an unprecedented season of national honors for the Red Raiders. Texas Tech’s most recent All-American prior to 2025 was Tyree Wilson, who earned first-team honors in 2022.
Texas Tech, which earned its first bid to the College Football Playoff, will face the winner of the first-round matchup between Oregon and James Madison on Dec. 20. The Red Raiders will play the victor in the CFP quarterfinals on Jan. 1 at the Capital One Orange Bowl.
To view the complete Sporting News All-America first and second teams, visit SportingNews.com.
Sporting News History
Founded in 1934, the Sporting News All-America Team—then awarded by The Sporting News—has long been one of college football’s most respected individual honors. Originally selected by panels of sportswriters, the team later incorporated evaluations from scouts and football observers as the sport evolved. Today, Sporting News is one of the NCAA’s five recognized selectors, with its first-team selections counting toward Consensus and Unanimous All-America status.
– TECH –
Oklahoma State’s 2025 season ended amid results and roster turnover that point to a program undergoing significant change.
The Cowboys finished 1-11 overall and 0-9 in Big 12 play, with an offense that struggled all season and a defense that failed to stop opponents.
The offense was led by freshman quarterback Zane Flores (1,450 passing yards, three touchdowns, seven interceptions), running back Rodney Fields Jr. (614 rushing yards, one TD), and wide receiver Gavin Freeman (481 receiving yards, four TDs).
Unfortunately, Flores has since declared his intention to leave the program.
On Monday, Flores officially announced plans to enter the NCAA Transfer Portal, becoming the latest Cowboy to depart and, according to local trackers, the 25th Oklahoma State player to enter the portal this cycle.
NEW: Oklahoma State QB Zane Flores plans on entering the NCAA Transfer Portal, @PeteNakos reportshttps://t.co/kNsiLKOWCK pic.twitter.com/dG0uBaCweF
— Transfer Portal (@TransferPortal) December 15, 2025
Some of the bigger names who also plan to leave include sophomore wide receiver Shamar Rigby, sophomore offensive tackle Grant Seagren, and tight ends Grayson Brousseau (freshman) and Josh Ford (sophomore), alongside a handful of young defensive backs, linemen, edge rushers, and receivers.
Rigby (the team’s third-leading receiver with 351 yards), Ford, and Seagren stand out as notable losses, as each was a regular starter and a highly touted three-star recruit.
Flores remains the most significant departure, however, as Oklahoma State’s starting quarterback and the No. 27-ranked quarterback in the 2023 class.
The season’s early turning point came on September 23, when Oklahoma State fired longtime head coach Mike Gundy after a 1-2 start.
Gundy had led the Cowboys for 21 seasons, compiling a 170–90 record and guiding the program to 18 consecutive bowl appearances.
Offensive coordinator Doug Meacham was named interim head coach, and the school later hired North Texas’ Eric Morris as its next head coach on November 25.
The coaching upheaval, Gundy’s dismissal, an interim stretch, and then a new hire set the backdrop for a midseason portal window and, ultimately, heavy roster attrition.
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