Tennessee guard denied preliminary injunction

Zakai Zeigler was denied a preliminary injunction in his pursuit of a fifth year of eligibility to return to Tennessee basketball after his four-year career ended.

“Plaintiff has failed to present sufficient evidence that the Four-Seasons Rule produces substantial anticompetitive effects in the market for student-athlete services and NIL compensation in Division I basketball,” wrote U.S. District Court Judge Katherine Crytzer in her June 12 ruling. The ruling followed a hearing June 6.

“What the NCAA should do as a policy matter to benefit student athletes is beyond the reach of the Sherman Act and TTPA and by extension, this Court,” she wrote.

Zeigler filed a lawsuit on May 20 seeking to return to college basketball in the 2025-26 season, including requesting a preliminary injunction on the grounds that he will suffer irreparable harm without immediate injunctive relief as schools are currently finalizing rosters and settling NIL agreements. It claimed Zeigler could earn up to $4 million if eligible in the 2025-26 season based on an analysis from Spyre Sports Group.

“We are disappointed the Court declined to grant a preliminary injunction on the basis that the NCAA does not directly control NIL compensation, just days after the House settlement confirmed they would do exactly that,” Zeigler’s attorneys said in a statement to Knox News through a spokesperson. “This ruling is just the first chapter of what we believe will ultimately be a successful challenge. We intend to press forward and are evaluating the best path ahead for Zakai.”

Zeigler’s lawsuit attacks the NCAA’s redshirt rule, which allows a player a fifth year of eligibility as long as the player sat out a year of competition. Zeigler played four consecutive seasons and did not redshirt but argues that he should be allowed a fifth year of eligibility and earning potential instead of being essentially punished for not redshirting.

It notes that the fifth year is “the most lucrative year of the eligibility window for the vast majority of athletes.”

“All NCAA athletes should be eligible to compete and earn NIL compensation during each year of the five-year window — not just those selected to redshirt,” the court filings state.

The lawsuit indicates that Zeigler is not challenging the five-year eligibility window, but the four-year competition window within the five years. It notes that Zeigler’s class is the first class in the NIL era to “have their ability to engage in commerce truncated to four years” because prior classes were granted an extra year due to the COVID-19 pandemic.

Zeigler, the filing states, “does not challenge the NCAA’s five-year eligibility window or argue that he should be able to compete for more than five years. He merely asks for the ability to compete for all five years of the NCAA’s eligibility window.”

In a filing June 2, the NCAA argued other athletes who have successfully sued the NCAA, such as Vanderbilt football’s Diego Pavia, sued for eligibility for seasons they weren’t a Division I athlete. Zeigler, however, has been a Division I athlete his entire collegiate career.

Zeigler, the NCAA argued, only got his chance to play at UT because another athletes exhausted their eligibility and opened up a roster spot for him. They called this the “lifecycle of a collegiate athlete.”

The NCAA argued that nothing would stop other athletes from suing the organization if it capped the eligibility at five years. They would sue to play for six years or seven years. It wouldn’t stop, they allege.

In a June 7 filing, Zeigler’s attorneys argued that the NCAA does not have the authority in the state of Tennessee to enforce its eligibility rules because of a new state law, but the judge largely sidestepped the argument altogether and said it would not be enough to grant the injunctive relief Zeigler sought.

“Instead, the law leaves enforcement in the capable hands of Tennessee’s ‘attorney general and reporter,'” Crytzer wrote. “Plaintiff therefore may not obtain a preliminary injunction based on a novel interpretation of the law.” 

The new Tennessee law, Senate Bill 536, allows Tennessee universities and athletes to opt out of NCAA rules if they appear to violate antitrust law. The initial purpose was to shift liability toward the NCAA and conferences and away from the schools in anticipated antitrust lawsuits by athletes unhappy with new player-pay rules in college sports.

But broad language in the law – which has not been litigated in any court – strips the NCAA of its power if the association prohibits a Tennessee athlete from earning money. Zeigler’s attorneys seized on that portion to push for a preliminary injunction that would grant him a fifth year of eligibility.

Zeigler averaged 11.3 points and 5.4 assists in his four seasons with the Vols. He shot 33.1% on 3-pointers.

Knox News reporters Tyler Whetstone and Adam Sparks contributed to this report.

Mike Wilson covers University of Tennessee athletics. Email him at michael.wilson@knoxnews.com and follow him on X @ByMikeWilson. If you enjoy Mike’s coverage, consider a digital subscription that will allow you access to all of it.