The House Settlement and the Coming Legal Reassessment of NCAA Eligibility Limits

The NCAA’s time-based eligibility rules — the five-year clock, the counting of JUCO seasons, and the redshirt framework — have long been treated as structural pillars of college athletics. For decades, these restrictions were insulated from legal scrutiny by the NCAA’s amateurism model and its academic-progress narrative. But the landscape has radically shifted. With the approval of the House v. NCAA settlement and the rapid rise of antitrust challenges across multiple circuits, the question of whether the NCAA can legally impose rigid tenure limits on athletes is now front and center.

The House settlement represents a seismic break from the past. In June 2025, Judge Claudia Wilken approved a deal requiring $2.6–$2.8 billion in back damages to athletes and authorizing schools to share roughly $20.5 million per year in direct revenue with their players. This is the first system in NCAA history that openly permits direct, institutional compensation for athletic performance. While athletes are not formally classified as employees under this settlement, the economic relationship between schools and athletes has undeniably shifted. The arrangement now carries the characteristics of a controlled labor market, weakening the NCAA’s historic argument that eligibility rules are purely academic and therefore shielded from antitrust review.

Within this new environment, the NCAA’s longstanding eligibility framework appears increasingly out of step. The rule granting athletes four seasons of competition within a five-year window — triggered by their first full-time enrollment — was originally justified on the premise that eligibility should track academic progress toward a bachelor’s degree. But when this framework is applied to athletes who spend time in junior-college programs, take redshirt years, or experience nontraditional academic paths, the logic becomes strained. JUCO athletes often complete academic work with no continuity to NCAA degree structures, yet their JUCO seasons are frequently counted against their Division I timeline. Redshirt seasons consume time without consuming competition. These inconsistencies are becoming more difficult for courts to ignore, especially now that each lost year of play equates to a quantifiable loss of NIL and revenue-sharing income.

Recent litigation reflects this shift in judicial attitudes. In Diego Pavia v. NCAA, a standout quarterback challenged the NCAA’s decision to count his junior-college seasons toward his Division I clock. A federal district court granted him relief, allowing him to compete in the 2025 season, and the Sixth Circuit later expressed open skepticism about the NCAA’s academic justification for counting JUCO time. Before the appellate court could issue a ruling, the NCAA mooted the case by issuing a waiver, but the legal issues remain alive in new pleadings seeking broader relief. Similarly, in other cases — including a growing class action involving Vanderbilt athletes — plaintiffs argue that the five-year window artificially shortens athletic careers, restricts earning capacity, and functions as a horizontal restraint on the supply of athlete labor.

Antitrust principles are becoming increasingly influential in these disputes. Once institutions are allowed to pay athletes directly, eligibility limits begin to resemble tenure caps in a labor market. Plaintiffs argue that restricting athletes to four seasons in five years — regardless of their academic standing or remaining competition seasons — reduces the amount of compensated athletic labor available in the market. Courts have not uniformly struck down these rules, but several have acknowledged that the economic consequences of lost eligibility are now real, measurable, and legally relevant. Even the courts that decline to provide immediate relief have signaled discomfort with rules that lack a coherent educational rationale or operate inconsistently across different athlete pathways.

The most vulnerable component of the NCAA’s eligibility structure may be the counting of JUCO seasons. Judges in the Sixth Circuit noted that tying JUCO participation to the NCAA five-year clock makes little sense when JUCO institutions do not offer four-year degrees and do not operate within NCAA academic architecture. This inconsistency undermines the NCAA’s principal justification for the clock. As courts increasingly demand rational, evidence-based explanations for eligibility limits—especially in a system where athletes are now compensated — rules that fail to align with their stated purposes are at risk.

Redshirt restrictions are also attracting judicial skepticism. Athletes in current lawsuits argue that redshirting preserves seasons of competition but still consumes calendar time, compressing the total duration of a playing career and limiting the athlete’s NIL potential. When eligibility rules directly cap the number of years an athlete can participate — and thus earn — those rules begin to resemble economic restraints rather than educational safeguards.

Taken together, these cases illustrate a national trend: courts are increasingly willing to interrogate the NCAA’s time-based rules, question whether they truly relate to academic priorities, and evaluate them through the lens of antitrust and labor-market principles. The NCAA has avoided definitive rulings by granting athlete-specific waivers and mooting cases, but this strategy is unlikely to hold indefinitely. The pressure is building, and the cracks in the system are becoming more pronounced.

For athletes and their representatives, this evolving landscape presents both significant opportunities and strategic considerations. Eligibility extensions — especially for JUCO athletes, medically affected athletes, or those whose timelines were disrupted by COVID-era delays — are now more attainable than ever. Strong cases often involve demonstrable academic progress, well-documented NIL impact, and clear evidence of arbitrary or inconsistent rule application. In the bigger picture, the House settlement empowers athletes to frame eligibility disputes as commercial restrictions on compensated labor, a narrative that courts are increasingly receptive to.

While the NCAA’s eligibility rules are unlikely to disappear overnight, gradual erosion is already underway. Courts are moving toward a model that evaluates eligibility limits through modern economic realities rather than outdated amateurism assumptions. As these legal challenges continue to unfold, athlete advocacy will play a critical role in shaping the next chapter of college sports.

Summary: What the House Settlement Means for NCAA Eligibility Rules

• The NCAA’s amateurism shield is weakening.
  The House settlement allows schools to pay athletes directly, making eligibility limits look more like restrictions in a labor market than educational policies.

• The five-year clock is facing serious legal scrutiny.
  Courts are increasingly questioning why athletes must complete their four seasons within five years—especially when they remain academically eligible and have untapped earning potential.

• Counting JUCO seasons is one of the NCAA’s most vulnerable rules.
  Judges have openly criticized the logic of applying a “four-year degree” timeline to athletes coming from two-year institutions with no NCAA academic alignment.

• Redshirt years create inconsistencies that harm athletes economically.
  Redshirts preserve competition seasons but still burn calendar time, shortening the total span of NIL-earning years—a point now central to litigation.

• Antitrust arguments are gaining traction.
  Athletes argue that eligibility rules cap the supply of athlete labor and limit their ability to participate and earn, raising Sherman Act concerns.

• Courts are increasingly receptive to athlete-specific relief.
  Cases like Diego Pavia v. NCAA show a willingness to grant waivers or injunctions when rules appear arbitrary or inconsistently applied.

• The NCAA is strategically mooting cases—temporarily.
  Waiving eligibility for individual athletes delays rulings but does not fix the underlying legal weaknesses in the system.

• Financial harms now matter more than ever.
  Because athletes can be paid directly and earn significant NIL money, lost seasons translate into quantifiable economic injury that courts take seriously.

• Reform will likely come gradually, not overnight.
  Expect incremental erosion: more waivers, more injunctions, and growing judicial skepticism toward rigid eligibility caps.

• Athletes have new avenues to challenge restrictions.
  JUCO transfers, medically impacted players, redshirted athletes, and those with disrupted timelines may all have viable claims for extensions or relief.