Eligibility After Alston: Why Pavia and Chambliss Won — and Aguilar Didn’t

Why It Matters

These cases illustrate that the post‑Alston antitrust lens can compel courts to intervene in NCAA eligibility rules, while state‑level challenges face higher hurdles, shaping the strategic path for athletes seeking NIL‑related relief and signaling broader pressure on the NCAA’s governance model.

Summary

The NIL era has turned NCAA eligibility into an economic right, prompting new litigation. Quarterback Diego Pavia secured a preliminary injunction in federal court by framing the NCAA’s rule counting junior‑college seasons toward the four‑year limit as an antitrust restraint, while Trinidad Chambliss won a state‑court injunction by alleging bad‑faith handling of his medical hardship waiver under contract principles. In contrast, Joey Aguilar’s challenge in Tennessee state court failed because he could not demonstrate a sufficient likelihood of success on the merits of his state antitrust and NIL claims, leading the judge to deny a preliminary injunction. The divergent outcomes highlight how forum choice and legal framing—federal antitrust versus state trade‑practice or contract theories—can determine relief in eligibility disputes.