In a significant setback for college athlete rights advocates and a personal blow to one of the University of Tennessee’s most decorated basketball players, a federal judge in Tennessee recently denied Zakai Zeigler’s request for a preliminary injunction. This injunction, if granted, would have allowed Zeigler to play a fifth season for the Volunteers while his broader antitrust lawsuit against the NCAA proceeded through the courts. Zeigler, a beloved figure in Knoxville and the Vols’ all-time leader in career assists (747) and steals (251), filed the lawsuit on antitrust grounds, contending that the NCAA’s “Four-Seasons Rule” unjustly prevented him from earning an estimated $2 million to $4 million in Name, Image, and Likeness (NIL) compensation during a potential fifth year of eligibility.
The “Four-Seasons Rule” is a fundamental NCAA bylaw, stipulating that student-athletes are permitted to participate in four seasons of competition within a five-year period, regardless of whether they have completed their undergraduate education or remain academically eligible. Zeigler, who graduated from the University of Tennessee after four impactful seasons, argued that this rule constituted an “unlawful restraint of trade” under federal and state antitrust laws. His legal team asserted that by limiting his eligibility, the NCAA was effectively locking him out of the lucrative NIL market for a year that, for many athletes, represents the peak of their earning potential dueability to their established brand and on-court performance.
Judge Katherine A. Crytzer, in her ruling, found that Zeigler had failed to meet the legal test required to secure a preliminary injunction. While the judge acknowledged that the NCAA’s eligibility rule is indeed subject to antitrust scrutiny, she determined that Zeigler had not sufficiently demonstrated that the rule produces “substantial anticompetitive effects” in the market for student-athlete services and NIL compensation. The court’s perspective emphasized that the NCAA does not directly control who receives NIL compensation, as these deals are struck between athletes and third parties. Therefore, the judge reasoned, Zeigler losing out on potential NIL earnings did not directly demonstrate that the NCAA was legally responsible for this economic outcome.
Furthermore, Judge Crytzer articulated that “this Court is a court of law, not policy,” indicating that her role was to interpret existing law, not to dictate what the NCAA “should do as a policy matter to benefit student athletes.” The ruling highlighted that Zeigler’s exclusion from college basketball, by virtue of replacing one Division I basketball player with another due to fixed roster spots, did not, in the court’s view, constitute a sufficiently meaningful anticompetitive effect from an antitrust law perspective. The judge also raised concerns that granting an injunction could potentially harm other currently enrolled Division I basketball players who have committed to institutions, as well as high school seniors vying for limited roster spots.
Zakai Zeigler’s case is distinct from others that have successfully challenged NCAA eligibility rules, such as the situation involving Vanderbilt quarterback Diego Pavia. Pavia, who started his career at a junior college, was granted an additional year of eligibility based on specific circumstances related to his junior college tenure not counting against his NCAA clock. Zeigler, however, had completed four full seasons of NCAA Division I basketball at Tennessee, making his request for a fifth year as a “matter of right” a precedent-setting demand for a player who had already exhausted the traditional eligibility window.
Despite the denial of the preliminary injunction, Zeigler’s legal team has promptly filed a notice of appeal to the Sixth Circuit, signaling their determination to continue the fight. They expressed disappointment with the court’s decision, particularly given the recent approval of the House v. NCAA settlement, which fundamentally reshapes the landscape of college sports by allowing direct payments from schools to athletes and acknowledging that NIL compensation is intertwined with athletic services. Zeigler’s lawyers contend that the ruling contradicts the spirit of the House settlement, which effectively confirmed the NCAA’s influence over athlete compensation. They believe this initial ruling is merely the “first chapter” of what they anticipate will be a successful challenge in the long run.
The antitrust arguments in Zeigler’s lawsuit align with a broader wave of legal challenges against the NCAA’s long-standing amateurism model. The House v. NCAA settlement itself, approved by a federal judge in California, is a direct result of three consolidated antitrust lawsuits that alleged the NCAA’s rules unlawfully restrained trade and suppressed athlete earnings. This historic settlement, which includes nearly $2.8 billion in back payments to former athletes for lost NIL compensation and permits schools to directly pay athletes within a capped revenue-sharing model starting in the 2025-26 academic year, underscores the NCAA’s shifting legal vulnerabilities.
However, Zeigler’s case specifically targets the “Four-Seasons Rule,” a separate facet of NCAA eligibility that, while seemingly distinct from direct compensation, his lawsuit argues has a direct impact on earning potential in the current NIL landscape. The argument posits that if an athlete’s eligibility is artificially limited, their window to maximize their NIL value is cut short, thus harming their economic opportunity. Zeigler, with his impressive statistics – not only his assist and steal records but also his consistent on-court production, including averaging 13.6 points and 7.4 assists in his last season, earning third-team All-American honors, and being a two-time SEC Defensive Player of the Year – clearly had a strong market value for another year. His lawsuit’s projection of $2 million to $4 million in NIL earnings was based on analysis from Spyre Sports Group, a prominent NIL collective associated with Tennessee.
The NCAA, in its defense, has consistently argued that eligibility rules are non-commercial in nature and are essential for maintaining the distinction between amateur and professional sports, promoting competitive balance, and ensuring opportunities for incoming student-athletes. They contend that allowing players to extend their eligibility indefinitely would fundamentally alter the collegiate model and create an imbalance in roster construction, potentially limiting opportunities for younger players.
Zakai Zeigler’s fight represents the cutting edge of legal battles challenging the traditional NCAA structure. As the landscape of college athletics continues to evolve at a rapid pace, driven by court rulings and the implications of NIL, his case will be closely watched. While the initial denial of the preliminary injunction is a hurdle, the decision to appeal signals that the broader legal challenge to the “Four-Seasons Rule” and its impact on athlete earnings is far from over. The outcome of Zeigler’s appeal could have significant ramifications for how long college athletes are permitted to compete and, consequently, how much they can earn in the ever-expanding world of Name, Image, and Likeness.
