NIL

NCAA Fights Zakai Zeigler’s Antitrust Suit, Defends Four-Seasons Rule

Published

7 months ago

June 3, 2025

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.

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NIL

Arch Manning takes NIL pay cut to boost 2026 Texas Football roster

Published

8 hours ago

December 20, 2025

Your Sports Nation

There are plenty of examples of a star in pro sports taking less money in order to help the overall roster. But it isn’t something that’s hit college football yet … until now, thanks to Arch Manning. Manning has asked to take a reduced portion of the Longhorns’ direct payout pool.

Manning’s aim at taking less NIL funds is to help improve the roster around him. Just like Patrick Mahomes, who regularly gives up millions to help the Kansas City Chief’s roster. Tom Brady did it with New England. Dirk Nowitzki, Tim Duncan, LeBron James, Kevin Durant, Jalen Brunson, Aaron Rodgers and Ben Roethlisberger have all helped the rosters around them by taking less.

In the pros, there are salary caps to negotiate. While college has no salary cap (yet), there is a finite amount in the NIL house pool. Texas can only spend what it has available. And while that pool is one of the biggest in the nation, Texas still follows a budget.

No doubt, Manning will be hoping the Texas coaching staff uses some of the freed up football revenue sharing funds on the offensive line. The line struggled in front of Manning all season and certainly inhibited his development early in the season.

Two offensive linemen are gone after the Citrus Bowl and Texas might lose a third. Left tackle Trevor Goosby was named first-team All-SEC is now contemplating going pro. Running back Jadan Baugh from Florida is also on Texas’ radar. The talented RB won’t be cheap.

Of course, it’s not like Manning will starve. The redshirt sophomore has one of the highest NIL valuations in nation. Manning has NIL deals with Red Bull, Panani, Uber and Warby Parker. Manning made north of $3.5 million in NIL deals in 2025, according to the Houston Chronicle.

With a big name that attracts major brands, Manning doesn’t need his big deals supplemented. But most college athletes are paid by the common pool of funds. Manning frees up some of that money for transfers.

This article originally appeared on Longhorns Wire: Manning Pay Cut: Texas QB asks for less NIL money to help boost roster

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Top 5 transfer portal landing spots for TCU quarterback Josh Hoover

Published

9 hours ago

December 20, 2025

Your Sports Nation

The NCAA Transfer Portal claimed another big name on Thursday night.

TCU star quarterback Josh Hoover has announced he intends to move on from the program. Hoover spent the last four seasons with the Horned Frogs, taking over as the starter midway through the 2023 campaign and putting up big numbers in each of the last two years.

In 36 career games, Hoover has completed 771/1183 passes for 9,629 yards with 71 touchdowns to 33 interceptions. He added eight more scores on the ground. There’s a very real likelihood that Hoover’s the most productive quarterback returning to the sport in 2026.

Hoover ranks in the top 5 in TCU program history in touchdown passes and total offense. He’s expected to be a coveted option in the portal.

Where are five landing spots that make sense for Hoover?

Indiana Hoosiers

Back in the College Football Playoff with a different starter for the second consecutive season, Indiana has put together one of the most impressive runs in the sport since Curt Cignetti took over the program.

The undefeated Hoosiers produced their first Heisman Trophy winner in school history last weekend as star quarterback Fernando Mendoza ran away with the award. Mendoza has another season of eligibility remaining, but is projected to be a top selection in the 2026 NFL Draft.

Indiana has already been linked to Hoover, per CBS Sports’ Chris Hummer.

Miami Hurricanes

Miami has lived in the transfer portal over the past few years, investing plenty of time and money into building a contender for Mario Cristobal. The moves finally worked out in 2025 as a massive financial commitment to secure Carson Beck from Georgia helped power the Hurricanes to the playoffs.

Though the conclusion of the 2024 season was a disappointment, former Miami quarterback Cam Ward was developed into the No. 1 pick in the most recent NFL Draft. Beck will likely get a shot at the professional level as well.

With little proven depth on the roster, it makes sense to bring in another experienced quarterback like Hoover to keep the Hurricanes on the right track. Miami has proven it’s willing to pay up.

Oregon Ducks

Oregon head coach Dan Lanning | Ben Lonergan/The Register-Guard / USA TODAY NETWORK via Imagn Images

Oregon is a known quarterback factory, sending former stars such as Marcus Mariota and Justin Herbert to the NFL. That hasn’t changed since Dan Lanning took over the program in 2022.

The Ducks have had a quarterback drafted in back-to-back years, with Bo Nix going in the first round in 2024 and Dillon Gabriel being selected within the top-100 picks in 2025. Lanning could do it again next April with Dante Moore, who is nearing the end of a career year.

If Moore does leap to the professional level, Hoover would be a solid fit. Nix, Gabriel, and Moore all began their college careers at different schools and later transferred to Oregon, a similar path Hoover is embarking on.

Texas Tech Red Raiders

Texas Tech head coach Joey McGuire | Nathan Giese/Avalanche-Journal / USA TODAY NETWORK via Imagn Images

Suiting up for a playoff contender is pretty cool. Having a chance to win championships and staying home in the process might be even cooler.

Texas Tech has firmly entrenched itself as a program to reckon with in the modern age of the sport. The Red Raiders have plenty of money, and they’ve shown they’re willing to use it to pull in elite talent from the transfer portal and high school ranks.

With Behren Morton exhausting his eligibility following the playoff run, Texas Tech has to decide if it wants to turn the program over to another transfer or a homegrown talent like Will Hammond.

Either way, Hoover is from Texas and he’s already in the state.

Houston Cougars

An outlier among four other programs that have a chance to win it all, Houston is on the come-up. The Cougars haven’t been shy about writing checks, evidenced by the program signing five-star quarterback Keisean Henderson during the Early Signing Period.

Redshirt junior starter Conner Weigman does have one season of eligibility remaining and has stated he intends to return next season. Decisions are quick to change in this era, so never say never.

Would Houston bring in Hoover while Henderson develops for a season? Or should the program stick with Weigman as a veteran leader for Henderson?

Weigman just joined the program as a transfer last year. He was fine, but unspectacular this fall, and an upgrade could help the Cougars break their ceiling.

South Carolina Upstate visits Youngstown State after Carroll’s 31-point outing

Published

10 hours ago

December 20, 2025

Your Sports Nation

South Carolina Upstate Spartans (8-6) at Youngstown State Penguins (7-5, 2-1 Horizon League)

Youngstown, Ohio; Saturday, 1 p.m. EST

BOTTOM LINE: Youngstown State hosts South Carolina Upstate after Cris Carroll scored 31 points in Youngstown State’s 80-77 overtime loss to the Robert Morris Colonials.

The Penguins are 4-0 on their home court. Youngstown State scores 80.2 points and has outscored opponents by 10.9 points per game.

The Spartans are 2-5 on the road. South Carolina Upstate is fifth in the Big South scoring 79.6 points per game and is shooting 46.2%.

Youngstown State averages 10.4 made 3-pointers per game, 3.8 more made shots than the 6.6 per game South Carolina Upstate gives up. South Carolina Upstate has shot at a 46.2% rate from the field this season, 3.3 percentage points greater than the 42.9% shooting opponents of Youngstown State have averaged.

TOP PERFORMERS: Carroll averages 3.0 made 3-pointers per game for the Penguins, scoring 16.4 points while shooting 48.6% from beyond the arc. Rich Rolf is averaging 10.8 points over the last 10 games.

Mason Bendinger is scoring 16.1 points per game and averaging 3.1 rebounds for the Spartans. Carmelo Adkins is averaging 1.9 made 3-pointers over the last 10 games.

LAST 10 GAMES: Penguins: 6-4, averaging 81.3 points, 33.6 rebounds, 15.2 assists, 9.1 steals and 3.3 blocks per game while shooting 49.6% from the field. Their opponents have averaged 67.7 points per game.

Spartans: 5-5, averaging 75.4 points, 33.5 rebounds, 14.1 assists, 6.1 steals and 5.0 blocks per game while shooting 43.9% from the field. Their opponents have averaged 73.2 points.

___

The Associated Press created this story using technology provided by Data Skrive and data from Sportradar.

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NIL

Arch Manning agrees to reduced NIL share to help Texas build roster

Published

11 hours ago

December 20, 2025

Your Sports Nation

In a college football world where NIL numbers keep climbing, Arch Manning is going the other way.

Arch Manning #16 of the Texas Longhorns reacts before the Texas Football Orange-White Spring Football Game

Photo by Tim Warner/Getty Images

The Texas quarterback has agreed to take a reduced share from the Longhorns’ revenue-sharing pool for the 2026 season, according to Justin Wells of Inside Texas. Manning was entitled to a full portion of the program’s revenue cap but opted to scale it back in an effort to give Texas more flexibility to strengthen its roster.

It is a move that stands out in the current landscape. It is also one Manning can afford to make.

Manning remains one of the most marketable players in college football and has a long list of endorsement deals that will continue to pay handsomely. Even with less money coming directly from the school, he is still expected to earn millions in 2026.

This is not the first time he has shown restraint, either. Manning has consistently been selective with his NIL opportunities since arriving in Austin.

The timing matters. The 2026 season is widely expected to be Manning’s last at Texas before he makes the jump to the NFL. From that perspective, the decision is straightforward. He wants the best possible team around him for one more run at a national championship.

Manning has already demonstrated his commitment to the program. He waited his turn behind Quinn Ewers for two seasons without entertaining a transfer and now is willing to sacrifice a portion of his compensation for the good of the roster.

On the field, the growth showed. After a shaky start in 2025, Manning finished with 2,942 passing yards and 24 touchdowns. Texas rebounded from a 3-2 opening to win six of its final seven games, punctuated by a decisive win over Texas A&M.

It is not a common move. It is a very Arch Manning one.

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Miami WR Malachi Toney inks NIL deal with Hellstar

Published

12 hours ago

December 20, 2025

Your Sports Nation

Ahead of the College Football Playoff opener, Malachi Toney added a notable NIL deal. The Miami wide receiver has inked a partnership with apparel company Hellstar.

Toney is Hellstar’s first NIL athlete, the Los Angeles-based brand said in an Instagram post. He became a crucial part of the Hurricanes’ offense during the regular season, helping lead the program to a College Football Playoff appearance as the last team in the field.

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It was part of a decorated freshman year for Toney, who’s emerging as one of the top young stars in the sport. Repped by NETWORK, he has a $878,000 On3 NIL Valuation.

“We are so proud to announce our first Hellstar Sports College Athlete NIL signing – Malachi Toney,” Hellstar wrote in its announcement. “We had the privilege to coach @malitoney10 while he was apart of our high school 7 on 7 program, so now seeing him shine on the collegiate level we couldn’t be more proud.

“We will continue to do our part to help these young athletes stay on the right path, and shine their light to the rest of the world. From Liberty City to the stars!”

It’s the latest notable NIL deal for Toney amid his freshman season. He also secured a partnership with Leaf Trading Cards in October.

More on Malachi Toney’s freshman season

Through his freshman year at Miami, Malachi Toney emerged as a top target for Carson Beck. He led the Hurricanes with 84 receptions for 970 yards, and his seven touchdown catches put him atop the ACC. Toney also added 89 rushing yards this year, as well as a rushing touchdown against Louisville.

Those numbers helped Toney become an On3 True Freshman All-American this year. In addition, he was a central figure in Miami’s run to the College Football Playoff.

“Toney’s quickness and playmaking instincts make him dangerous after the catch. He accounted for 350 yards after the catch with an average depth of target of 6.6, according to Pro Football Focus,” On3 | Rivals’ Charles Power wrote. “Whether working out of the slot or moving around the formation, the South Florida native has proven nearly impossible to contain. His playmaking ability was pivotal to Miami’s playoff push as he became the focal point of the Hurricanes’ passing attack.

“Given his play as a true freshman, it’s safe to say the Fort Lauderdale American Heritage product will enter next season as one of college football’s premier wide receivers. Toney’s performance as a true freshman is even more impressive considering that he should still be in high school, having reclassified into the 2025 cycle late in the recruiting process.”

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Arch Manning taking pay cut after first Texas season didn’t go as planned

Published

13 hours ago

December 20, 2025

Your Sports Nation

Arch Manning is taking a pay cut.

The Texas quarterback agreed to take a reduced share of the team’s revenue-sharing pool “as part of an effort to help the Longhorn football program do whatever it takes to support a 2026 championship run,” according to On3’s Justin Wells.

The savings “could be used on transfer portal talent or as part of retention efforts” for the Longhorns, per Wells.

This season, athletic programs were capped at $20.5 million in revenue-sharing, although that number is likely to increase next season and beyond.

AUSTIN, TEXAS - NOVEMBER 28: Arch Manning #16 of the Texas Longhorns looks on during the third quarter against the Texas A&M Aggies at Darrell K Royal-Texas Memorial Stadium on November 28, 2025 in Austin, Texas. (Photo by Alex Slitz/Getty Images) — Arch Manning #16 of the Texas Longhorns looks on during the third quarter against the Texas A&M Aggies at Darrell K Royal-Texas Memorial Stadium on November 28, 2025 in Austin, Texas. Getty Images

Manning, the nephew of NFL icons Peyton and Eli Manning and the grandson of legendary quarterback Archie, is one of the most marketable athletes in college sports.

On3 currently gives Manning an NIL valuation of $5.3 million, which leads all student-athletes.

Although he is getting less money from Texas, Manning still holds NIL deals with brands like Red Bull, Uber and EA Sports, among others.

However, Manning sometimes struggled in a season that started with Heisman hype and the Longhorns ranked No. 1 in the nation.

Texas finished the season 9-3 and out of the College Football Playoff, a disappointing midseason loss against a poor Florida team all but ended their chances of being in the 12-team field.

Manning’s season was underwhelming as well, throwing for 2,942 yards with 24 touchdowns and seven interceptions.

The news comes after Manning’s father, Cooper Manning, told ESPN earlier this week that his son would return to the Longhorns in 2026 for his junior season despite previously mulling entering the 2026 NFL Draft.

“Arch is playing football at Texas next year,” Cooper said.

Texas finished No. 13 in the end of season rankings and will be on the sidelines for the College Football Playoff, which kicks off on Friday.

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