NCAA Scores Major Win in Court

As sports law fanatics know, the NCAA has been sued. A lot.

And they’ve suffered many brutal losses.

Perhaps the infamous loss (at least in recent years) was the U.S. Supreme Court delivering a unanimous decision in favor of the plaintiffs in Alston, where Supreme Court Justice Brett Kavanaugh notoriously ended his concurrence: “The NCAA is not above the law.”

But the NCAA isn’t winless in court.

Earlier this week, the NCAA scored a major win in court when a New York U.S. District Judge dismissed a case brought by sixteen ex-college athlete plaintiffs, including former Kansas basketball star Mario Chalmers.

Plaintiffs’ complaint broadly alleges that the NCAA, and its member schools and conferences, exploited their NIL rights, during and after college, without compensating them.

Notably, the plaintiffs argue the NCAA’s collusive and monopolistic conduct occurred before June 15, 2016 — the beginning of the eligibility period for beneficiaries of the pending House settlement.

The judge’s decision to dismiss the case could have significant implications: the NCAA may try to use the ruling to dismiss lawsuits that other former student-athletes have initiated over lost NIL chances.

Here’s a breakdown of the judge’s ruling:

Judge Engelmayer’s Ruling

U.S. District Judge Paul A. Engelmayer issued a 34-page Opinion & Order that granted the NCAA’s motion to dismiss the lawsuit.

As part of the background, Judge Engelmayer noted that Chalmers was part of the Keller settlement class, ten plaintiffs were part of the Alston settlement class, and all 16 were part of the O’Bannon injunctive class.

Here are the major points Judge Engelmayer focused on:

Statute of Limitations/Timeliness

NCAA argued: the amended complaint falls outside the Sherman Act’s four-year statute of limitations

Plaintiffs argued:

• through the “continuing violation doctrine,” although plaintiffs were harmed many years ago, each ensuing use of a plaintiff’s NIL restarts the limitations period

• through the “speculative damages” doctrine, the accrual date for their claims should be treated as the day their NIL was used, which falls within four years of the lawsuit

• the doctrine of equitable estoppel tolled the running of the statute of limitations of their claims

Judge held: none of plaintiffs’ theories is persuasive and none makes plaintiffs’ claims, based on conduct 10-30 years ago, timely

Score: NCAA 1-0 Plaintiffs

Preclusion

NCAA argued: plaintiffs claims are precluded, based on O’Bannon (bars the claims for injunctive relief) and Alston (settlement release bars the damages claims of 10 plaintiffs)

Plaintiffs argued: their complaint alleges broader price-fixing allegations than those adjudicated in O’Bannon and a different §1 horizontal conspiracy than Alston 

Judge held: NCAA, on both points, “have by far the better argument”

Score: NCAA 2-0 Plaintiffs

Unjust Enrichment

Plaintiffs argued: the NCAA and conference defendants unjustly retained ownership of plaintiffs’ NILs and profited off of them

NCAA argued: the unjust enrichment claim should be dismissed

Judge held:

• the unjust enrichment claim duplicates the antitrust claims, which have been dismissed

• the unjust enrichment claim is untimely (six-year statute of limitation period)

Score: NCAA 3-0 Plaintiffs

A clean sweep for the NCAA.

Looking Ahead + My Thoughts

I’m not sure who or what factors went into deciding House settlement eligibility boundaries.

But are college athletes who competed before June 15, 2016 just out of luck?

Forgive me as I’m not a House settlement expert, but based on my understanding, college athletes who played before June 2016 aren’t eligible for any backpay or other compensation stemming from the House settlement.

Sure, those athletes can bring separate legal action — like plaintiffs did here — but based on Judge Engelmayer’s ruling, I’m not sure how successful they will be.

Timeliness and preclusion seem to be the core points of Judge Engelmayer’s ruling, and I’d imagine other prospective plaintiffs suing for pre-2016 los NIL chances may run into the same issue.

I’ll be keeping my eyes on other former athletes who have ongoing lawsuits against the NCAA, like Kris Jenkins, Reggie Bush, and Terrelle Pryon, to see if the NCAA can convince courts to dismiss those actions as they did here.

Curious to hear your guys thoughts on this. Feel free to directly reply to this email.

Conversation Starters 🗣️

Fox Sports Fires Executive Named in Two Lawsuits 📃

On Monday, Fox Sports fired FS1 Exec Charlie Dixon, who was accused of assault by multiple employees in lawsuits filed earlier this year. Fox had been in settlement talks via mediation for both lawsuits and had initially suspended Dixon in February.

Judge Rules for Rutgers Transfer Player Over Eligibility  

A federal judge granted Rutgers football transfer Jett Elad a preliminary injunction, allowing the DB to play in the upcoming season. Pointing to antitrust law and NIL deals, NJ District Judge Zahid N. Quraishi found Elad’s commercial opportunities, including a $500k+ NIL deal, were crucial. Across the country, judges have been granting — and declining to grant — injunctions sought by players with prior community college experience.

Mistrial declared in Ex-Canadians Sexual Assault Case 🏒

A judge declared a mistrial in a case involving five former players of Canada’s world junior hockey team who all pleaded not guilty to charges. No reason for the mistrial has been reported due to “a standard legal ban against publicizing trial proceedings that take place without the jury present.” None of the players involved are on an NHL roster or have an active contract with an NHL team.

The NBA playoff ratings have been wayyy up this year (with ESPN reporting a 13% increase from last year). The first-round matchups have felt like decades-long rivalries with at least one fight per game.

I have to confess I haven’t been tuning into the NHL playoffs (yet), but mid-April through June has to be one of the best times of the sports calendar.

Go Celtics,

Duggs

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Sources:

https://www.courthousenews.com/wp-content/uploads/2025/04/chalmers-ncaa-antitrust-dismissal-order.pdf

https://www.sportico.com/law/analysis/2025/ncaa-defeats-mario-chalmers-nil-lawsuit-1234850280/

The Sideline’s work, including this article, is for information purposes only and should not be construed as legal advice. This article does not create an attorney-client relationship. The opinions expressed in the article belong solely to the author and do not express the views or opinions of the author’s employer.