Ninth Circuit: Vacates Injunction on NCAA Five-Year Rule

• The Ninth Circuit recently issued two opinions addressing antitrust challenges to the NCAA's five-year eligibility rule.
• In `Braham v. NCAA`, the court dismissed a consolidated appeal as moot because the injunctions had expired and the athletes' collegiate careers concluded.
• The panel vacated a preliminary injunction in `Blythe v. NCAA`, finding the lower court erred in its antitrust analysis.
• Judge Gabriel Sanchez's opinion in `Blythe` cited a lack of evidentiary support for anticompetitive effects and an improper definition of the relevant market.
• These rulings indicate a higher evidentiary bar for obtaining preliminary injunctions against NCAA eligibility rules under the Sherman Act.

The appellate court specifically highlighted the lower court's errors in assessing the likelihood of success on the merits of the Sherman Act claim, particularly due to sparse evidentiary support, and its flawed definition of the relevant market.

The Ninth Circuit Court of Appeals recently weighed in on two significant appeals concerning the NCAA's five-year eligibility rule, delivering rulings that clarify the high bar for challenging such regulations under antitrust law. In a pair of opinions issued on Wednesday, the appellate panel addressed claims brought by college athletes seeking to extend their playing careers beyond the NCAA's established limits. These decisions underscore the complexities of `NCAA eligibility antitrust claims` and the evidentiary hurdles plaintiffs face when pursuing injunctive relief.

One ruling dismissed a consolidated appeal as moot, while the other vacated a lower court's preliminary injunction that had temporarily halted enforcement of the `NCAA five-year rule` for a college baseball player. Both opinions, penned by U.S. Circuit Judge Gabriel Sanchez, provide crucial guidance for future `Sherman Act college athletics` disputes, particularly regarding the standards for proving anticompetitive effects and defining relevant markets. The cases, `Braham v. NCAA` and `Blythe v. NCAA`, represent key developments in the ongoing legal battles over collegiate athletic eligibility.

In `Braham v. NCAA`, a consolidated appeal involving college football players Cortez Braham and Tatuo Martinson, the Ninth Circuit panel concluded that the case was moot. Judge Sanchez's 12-page opinion explained that the preliminary injunctions previously issued to stop the enforcement of the `NCAA five-year rule` had already expired. Furthermore, both players had concluded their collegiate athletic careers, rendering any further judicial intervention in their specific cases unnecessary.

Braham and Martinson initiated their college journeys in 2019 at junior colleges before transferring to and competing for NCAA Division I institutions. They had each utilized the maximum five years of collegiate enrollment eligibility permitted under NCAA regulations. Their legal challenge targeted the `NCAA five-year rule`, which restricts athletes to four seasons of eligibility within five years of their initial college enrollment, alleging violations of the Sherman Act. Despite the dismissal, the attorney representing the players, Gregg Clifton, acknowledged the Ninth Circuit's thorough review of the record. Judge Sanchez noted that other cases challenging the same rule, brought by athletes from various sports, remain active on appeal, though many of these plaintiffs had not secured preliminary injunctions.

The second, more substantively impactful decision came in `Blythe v. NCAA`, where the Ninth Circuit vacated a `Ninth Circuit preliminary injunction` that had allowed college baseball player Noah Blythe to compete. In his 22-page opinion, Judge Sanchez identified several critical errors in the lower court's analysis. The appellate court specifically highlighted the lower court's errors in assessing the likelihood of success on the merits of the Sherman Act claim, particularly due to sparse evidentiary support, and its flawed definition of the relevant market.

The district court had incorrectly defined the relevant market as the Division I collegiate baseball labor market and, consequently, erred in finding that Blythe had met his burden to demonstrate a substantial anticompetitive effect within that market. Blythe's athletic history included playing for a few years at Hawaii Pacific University, an NCAA Division II institution, and three years at the University of Antelope Valley, a school associated with the National Association of Intercollegiate Athletics (NAIA) rather than the NCAA. After transferring to the University of Nevada, Reno, an NCAA Division I baseball program, his request for a waiver of the `NCAA five-year rule` for the 2026 season was denied by both the conference and the NCAA. When oral arguments were heard on March 13, Blythe was actively playing in the 2026 season due to the now-vacated preliminary injunction.

These recent `Gabriel Sanchez NCAA ruling`s from the Ninth Circuit carry significant implications for athletes and institutions navigating `NCAA eligibility antitrust claims`. The `Blythe v. NCAA` decision, in particular, establishes a higher evidentiary bar for plaintiffs seeking preliminary injunctions against NCAA rules under the Sherman Act. Lawyers advising college athletes or institutions on `NCAA eligibility disputes`, particularly those involving antitrust challenges, must be aware of the high evidentiary bar for proving anticompetitive effects and carefully defining the relevant market in the Ninth Circuit.

The appellate court's emphasis on the "dearth of evidence" regarding anticompetitive effects and the precise definition of the relevant market signals increased difficulty in obtaining `Ninth Circuit preliminary injunction`s against NCAA rules based on `Sherman Act college athletics` claims. While the `Braham` case was dismissed on mootness grounds, the `Blythe` ruling provides substantive legal precedent, reinforcing the NCAA's position against broad antitrust challenges to its eligibility criteria. This judicial posture suggests that future plaintiffs will need to present robust evidence and meticulously define their claims to overcome the legal hurdles in challenging the `NCAA five-year rule` and similar regulations.

Lawyers advising college athletes or institutions on NCAA eligibility disputes, particularly those involving antitrust challenges, must be aware of the high evidentiary bar for proving anticompetitive effects and carefully defining the relevant market in the Ninth Circuit. This ruling indicates increased difficulty in obtaining preliminary injunctions against NCAA rules based on Sherman Act claims.

Source: Original reporting via Courthouse News Service