The Tennessee judge who paved the way for Vanderbilt quarterback Diego Pavia to play college football this season denied a request for a preliminary injunction to a group of athletes who are challenging the NCAA’s redshirt rules with a lawsuit seeking a fifth year of eligibility.
U.S. District Judge William L. Campbell’s ruling means 19 plaintiffs, including Vanderbilt linebacker Langston Patterson, remain without eligibility to compete at NCAA schools in 2026-27. The four plaintiffs who joined Patterson in seeking a preliminary injunction were kicker Nathanial Vakos (Wisconsin), long snapper Nick Levy (Wisconsin), tight end Lance Mason (Wisconsin) and long snapper Kevin Gallic (Nebraska).
The case will move forward, but whether it can do so quickly enough to be resolved in time for the athletes to compete next season seems unlikely.
Pavia’s lawsuit, which challenged rules that count seasons of junior college competition against an athlete’s NCAA eligibility clock, was filed in November 2024. Campbell granted Pavia’s request for an injunction about a month later, which allowed him to play a second season at Vanderbilt after spending two seasons at a JUCO and two at New Mexico State.
Pavia’s attorney, Ryan Downton, filed the lawsuit challenging the NCAA’s redshirt rules, seeking five years of full participation for all athletes, in September. With college athletes now permitted to be paid for use of their names, images and likenesses, including a new revenue-sharing system that allows direct payments from schools to athletes, the redshirt rules amount to a violation of antitrust law, according to the lawsuit.
Currently, the NCAA allows athletes four full seasons of competition to be completed over five years in school. Athletes can practice and train with their teams and compete in a limited number of games — four is the cut-off for football — in one year while still maintaining four years of eligibility.
The preliminary injunction would not have extended beyond the named plaintiffs in the case.
The NCAA informed its member schools last month that it did not plan on issuing a blanket waiver that would grant all current athletes a fifth year of eligibility for next school year, regardless of whether they have already taken a redshirt year. Such a waiver would have opened the door to thousands of athletes otherwise out of eligibility potentially returning to school next year.
The idea of changing NCAA rules and moving to five years of full eligibility for all athletes has been discussed in the past, but with college sports in the midst of wide-ranging changes to the ways athletes can be compensated, formal discussions about revamping eligibility rules have been shelved. This week at the annual American Football Coaches Association conference, coaches recommended allowing players to appear in up to nine games (regular season or postseason) and use their redshirt, instead of four. The recommendation is not an official NCAA proposal but will be put in front of NCAA committees.
NCAA eligibility rules have been in the crosshairs for the past year, starting with Pavia’s lawsuit.
Campbell, the Chief Judge of Tennessee’s middle district in Nashville — where Vanderbilt is located — granted Pavia a preliminary injunction in December 2024. The narrow ruling allowed Pavia to play this season, and the 23-year-old went on to lead Vanderbilt to a 10-3 record and finished second in the Heisman Trophy voting to winner Fernando Mendoza of Indiana.
After Campbell’s ruling in the Pavia case, the NCAA approved a blanket waiver that gave an additional year of eligibility in 2025-26 to former JUCO athletes with similar circumstances to Pavia.
A preliminary injunction provides immediate relief in cases where a plaintiff would be harmed by waiting for a lawsuit to play out in court. A trial date has not yet been set in the Pavia case. He has said he is done with college football and plans to pursue an NFL career after two years in junior college, two more at New Mexico State and two at Vanderbilt.
About 30 more lawsuits have followed since Pavia’s, challenging various aspects of NCAA eligibility, producing a variety of rulings, many in favor of the NCAA.
None have sought to strike down all eligibility rules, but every case chips away at the NCAA’s authority and creates uncertainty about who can compete.
Several recent rulings by the NCAA, allowing basketball players with professional experience outside the NBA to join college rosters, have been sharply criticized by coaches — though NCAA rules have long allowed some leeway for former pros to compete in college.
Most notably, Baylor men’s basketball made a midseason addition of James Nnaji, who was selected 31st overall in the 2023 NBA Draft but never played in a regular-season NBA game.
Meanwhile, the NCAA denied Ole Miss’ waiver request to extend the eligibility of quarterback Trinidad Chambliss to cover a sixth year. Chambliss spent four years at Division II Ferris State, before transferring before the 2025 to the SEC school, where he became an unlikely star of a College Football Playoff team.
Chambliss did not play in a game either of his first two seasons at Ferris State, before playing 25 games over the final two. Ole Miss sayid the 2022 season should be treated as a medical redshirt. The school has appealed, and Chambliss’ lawyers are expected to file a lawsuit challenging the rules in Mississippi court.