High School, High Stakes: Calhoun v. CIF and the NIL Clash to Come

[1]

On May 30, 2025, Dominik Calhoun, a former three-star football recruit from Pittsburg High School and incoming Boise State freshman, filed a landmark federal antitrust class action lawsuit against the California Interscholastic Federation ("CIF") and its media partners. This case represents significant legal challenges to high school sports governance in the NIL era.[2] Calhoun’s suit, Calhoun v. California Interscholastic Federation, et al. is currently before the U.S. District Court for the Northern District of California and marks the first serious effort to extend collegiate NIL legal principles and analysis to the high school level.[3]

At the heart of Calhoun's lawsuit is a familiar argument among sports attorneys: NIL restrictions, when coordinated among powerful governing bodies and commercial partners, constitute an unreasonable restraint of trade under Section 1 of the Sherman Act.[4] The complaint alleges that CIF, along with business partners like Spectrum SportsNet and software providers managing broadcasting and ticketing infrastructure, have exploited high school athletes' labor and marketability for commercial gain without sharing the revenue.[5]

California is one of 41 states that currently allow some form of high school NIL monetization.[6] However, the CIF has implemented deeply restrictive policies for its athletes.  Athletes are prohibited from using school logos, uniforms, or even referencing their school in NIL deals, drastically reducing their commercial value.[7] Moreover, CIF restricts direct compensation for athletic performance to $250 for regular season competition and $500 in postseason play, both of which amount to minimal compensation which pale in comparison to the millions generated by broadcasting contracts and event sponsorships.[8]

Calhoun's lawyers, Yaman Salahi and Joel Benjamin Young, argue that CIF and its partners have formed a "zero-price cartel" whereby the economic value of student-athletes' NIL is captured entirely by the league, schools, and broadcasters.[9] In practical terms, this means that while student-athletes’ performances and identities generate significant commercial value through broadcasting rights, ticket sales, and sponsorships, the CIF’s rules prevent athletes from receiving any share of that revenue.[10] By prohibiting meaningful NIL deals and capping direct compensation at token amounts, the CIF effectively fixes the athletes’ NIL price at zero, allowing the league, schools, and media companies to capture all of the economic benefits for themselves.

Calhoun’s complaint explicitly references the NCAA's now-infamous compensation model, and draws legal connections to notable cases such as O'Bannon v. NCAA, Alston v. NCAA, and most recently House v. NCAA, which led to a proposed $2.8 billion revenue-sharing settlement for college athletes.[11]

The lawsuit seeks to certify a class including all CIF athletes who participated in competition from May 30, 2021, through the final judgment of the case, potentially implicating hundreds of thousands of current and former high school athletes.[12] More importantly, the lawsuit aims to have the court invalidate several of CIF’s rules, including restrictions on NIL usage, bans on performance-based pay, limits on transfers for athletic reasons, and collective-like booster activity. A driving force in Calhoun’s decision to bring the lawsuit, these changes would effectively challenge the regulatory backbone of high school amateurism in California.[13] Structurally, the CIF is a nonprofit governing body with broad jurisdiction over 1,600 schools and ten regional sections. However, even with the serious implications attached to this suit, they are yet to comment publicly.

In 2012, CIF entered into a 15-year, $8.5 million deal with Spectrum to televise California high school games, creating a revenue structure centered on student-athlete performance, with no compensation flowing back to the athletes themselves.[14] Moreover, commercial software vendors profiting from digital ticketing, stats services, and school-branded content are now named as co-defendants.[15]

Calhoun’s personal experience with NIL illustrates the significance of this lawsuit. Now under contract with Boise State, he is already earning NIL revenue through autograph sessions and collective-led marketing efforts. He argues he could have monetized his brand sooner, had CIF policies not precluded it.[16] In other words, the suit does not merely challenge the legality of restrictions, but it also alleges measurable economic harm which is a powerful factor in antitrust jurisprudence post-Alston.[17]

Legal observers see the case as a potential "NIL v2.0" moment. Amanda Christovich of Front Office Sports reported that a win for Calhoun could lead to a national shift toward less restrictive high school NIL frameworks, mirroring the post-Alston deregulation wave that swept through collegiate athletics.[18] If the court finds CIF's policies unreasonably restrictive or inherently anticompetitive, state associations across the country may soon face similar lawsuits.

Yet challenges abound. Courts may consider the unique status of high school students, many of whom are minors, and the state’s interest in preserving academic integrity and parity in competition. CIF may argue, as the NCAA once did, that amateurism and uniform governance are essential to the educational mission of scholastic sports.[19] But if “the House settlement” has taught us anything, it is that judicial patience for blanket restrictions (especially those masking commercial motivations) is wearing thin.

Ultimately, Calhoun v. CIF is more than a test of NIL rights. It is a referendum on the economic architecture of high school sports. Should schools and vendors profit from student-athlete value without compensation? Should CIF dictate terms in a rapidly professionalizing landscape? Whether this case settles, wins, or loses, one thing is clear: NIL litigation has officially reached the high school level, and Dominik Calhoun is leading the charge.

Nick Briggs (staff writer) is a 2L at Villanova University Charles Widger School of Law. Originally from Upstate New York, he roots for a variety of professional sports teams but none more than the rebuilding New England Patriots. He is a 1L representative for the Entrepreneurship Law Society (ELS), as well as an avid member of the Sports Law Society (SLS) and Villanova Italian-America Legal Organization (VIALO).

References:

[1] Bill Morson. (February 19, 2015). Flickr.

[2] Calhoun v. Cal. Interscholastic Fed'n, No. 3:25-cv-04603 (N.D. Cal. May 30, 2025), Compl.

[3] Alex Lawson, Class Action Seeks Compensation For High School Athletes, Law360 (June 2, 2025), https://www.law360.com/articles/2347954.

[4] Id.

[5] Calhoun at ¶ 5.

[6] Bob Lundeberg, Boise State Football Signee Files NIL Class-Action Lawsuit, Sports Illustrated (June 6, 2025), https://www.si.com/college/boise-state/football/boise-state-football-signee-files-nil-class-action-lawsuit.

[7] Calhoun at ¶¶ 44–47.

[8] Id. at 51.

[9] Id. at 54-56.

[10] Id.

[11] In re College Athlete NIL Litigation (House v. NCAA), No. 4:20-cv-03919 (N.D. Cal. 2024)

[12] Calhoun at ¶ 62.

[13] Id. at ¶53-60

[14] Alex Lawson, Class Action Seeks Compensation For High School Athletes, Law360 (June 2, 2025), https://www.law360.com/articles/2347954.

[15] Student-Athlete NIL Alert: CA High School Athletes File Class Action, PI&B Law (June 5, 2025), https://www.piblaw.com/newsroom-news-610.

[16] Bob Lundeberg, Boise State football signee files NIL class-action lawsuit, SI Boise State Broncos (June 6, 2025), https://www.si.com/college/boise-state/football/boise-state-football-signee-files-nil-class-action-lawsuit.

[17] NCAA v. Alston, 141 S. Ct. 2141 (2021).

[18] Bob Lundeberg, Boise State football signee files NIL class-action lawsuit, SI Boise State Broncos (June 6, 2025), https://www.si.com/college/boise-state/football/boise-state-football-signee-files-nil-class-action-lawsuit.

[19] PI&B Law, Student-Athlete Name, Image and Likeness (NIL) Alert - California High School Athletes Bring Federal Class Action Lawsuit Seeking Rights to Performance and NIL Revenue (June 5, 2025), https://www.piblaw.com/newsroom-news-610.