The NCAA was granted an important -- albeit temporary -- win by the courts after a judge has denied former(?) Tennessee point guard Zakai Zeigler's request for an injunction to play a fifth season of college basketball.
When Vanderbilt quarterback Diego Pavia sued in December to challenge the NCAA's 5-to-play-4 eligibility rule, he did so under the argument that he began his post-high school career at the junior college level, and that NJCAA athletes should not be bound by NCAA rules. The courts agreed.
Zeigler's case is different in that there were no extenuating circumstances in his college career. He signed with Tennessee out of high school in 2021-22 (after covid), played all four seasons for the Vols, and played a lot. He played 35 games in 2021-22, 30 in 2022-23, 36 in 2023-24, and 37 in 2024-25. No string of injuries, no coaching changes, no nothing. His legal argument is essentially that he can make lots of money by playing a fifth season of college basketball, and under the Sherman Antitrust Act limiting restrictions to free trade, he should be allowed to.
The legal argument, as this non-lawyer understands it, is that being a college basketball player is a job no different than being a plumber or a doctor, and there's no law saying plumbers can only profit from their trade four times over a 5-year period.
And in denying Zeigler's specific argument, the courts may have ultimately given a win to the argument that a 4-year limit on playing college athletics is an illegal restriction of trade.
This decision may prevent similar lawsuits, where athletes who played 4 seasons of DI are seeking additional seasons.
— Mit Winter (@WinterSportsLaw) June 12, 2025
But it’s another decision holding that NCAA eligibility rules are commercial in nature and subject to antitrust law.
Full order👇https://t.co/IjdcU96EUs
Oh yeah this is very much a "there hasn't been enough evidence presented... yet" type of ruling. pic.twitter.com/YGV2X5ooW9
— Sam C. Ehrlich (@samcehrlich) June 12, 2025
Although Zakai Zeigler’s request for a preliminary injunction was denied, the court ruled against the NCAA on an important point with respect to these athlete eligibility cases.
— Mit Winter (@WinterSportsLaw) June 12, 2025
It held the 4 seasons of competition rule and other eligibility rules are subject to antitrust law. https://t.co/YyXYqB202x pic.twitter.com/YQnhtzq7Qp
Zeigler's lawsuit claims he plans to enroll in a graduate program this fall and "compete in one final season of college basketball." If able to do so, Zeigler will receive "significant (NIL) compensation."
But if he has the legal standing to play a fifth season, what's stopping him from playing a sixth, a seventh, an eighth? We may find out soon.