Players Against the NCAA Four Seasons Rule in the NIL Era

[1]

In May 2025, University of Tennessee point guard Zakai Ziegler filed a lawsuit against the NCAA, alleging that the organization violated the Sherman Act by denying his eligibility to play a fifth season.[2] Ziegler played four consecutive seasons at Tennessee, winning Defensive Player of the year in the Southeastern Conference twice.[3] In denying him the right to play a fifth year while he pursues a graduate degree at the university, Ziegler claims he is losing the opportunity to earn between $2 and $4 million through name, image, and likeness ("NIL").[4]

How Ziegler Differs from Other Fifth Year Players

While it is common for student athletes to seek a fifth year of eligibility, Ziegler’s lawsuit is unique because of his continuous player status.[5] Players who are granted eligibility typically have   transferred between schools or divisions during their collegiate career.[6] This often occurs when players “redshirt” a season, meaning they do not compete with the team, but they practice alongside them.[7] Zeigler argues that these players can benefit from five years of NIL compensation, whereas he is limited to only four years despite consistent participation.[8] 

Over the past two years, dozens of players have filed suits against the NCAA , but Zeigler is the only one to have played four consecutive seasons at the same institution and without “redshirting” .[9] The NCAA requires graduation in six years to promote academic achievement. Zeigler contends that prohibiting him from competing a fifth year while pursuing a graduate degree undermines the NCAA’s own academic and organizational goals.[10]

Antitrust Considerations and Impact

The NCAA faces increasing scrutiny for violating anti-trust laws, as critics argue that the four-season rule restricts athletes’ ability to earn income.[11] This issue has become more prevalent since the establishment of NIL because athletes can monetize their collegiate careers.[12] Criticism of this argument holds that allowing Zeigler to play a fifth season will set a precedent that will limit the opportunities of incoming students.

In his case, he failed to demonstrate that replacing experienced players like himself with experienced recruits has a substantial anticompetitive effect on the market for college athletes.[13] Although Zeigler dropped his bid to play a fifth season, other players have been filing similar lawsuits against the NCAA.[14]

If the court had granted his injunction to play another year, the action would harm high school students currently committed to the school to play, given that there is a limited number of roster spots on these collegiate teams.[15] Harm to incoming and prospective players would undermine the NCAA’s mission to expand opportunities for new athletes to compete at the collegiate level.

Critics argue that if the NCAA sets a precedent of allowing extended eligibility, the association will lose the power to limit the careers of players in the future, leading to a decrease in opportunity for younger students.[16] For now, the current eligibility rule remains intact, and Zeigler’s attempt to extend his playing career has been denied. [17]

Devon Fagan (staff writer): I attended the University of Florida for undergrad, where she enjoyed attending basketball, football, and baseball games. She is passionate about college sports and how NCAA policies impact athletes.

References:

[1] Photo by Gene Gallin on Unsplash: https://unsplash.com/photos/orange-basketball-on-brown-wooden-floor-u_yi-1kUh2o

[2] Teresa M. Walker, Zakai Zeigler, SEC’s 2-time defensive player of year, suing NCAA to play 5^th season in 5 years, Associated Press (May 25, 2025), https://apnews.com/article/ncaa-tennessee-zakai-zeigler-lawsuit-667701cfa8ab30dd6a7b66cc28930699

[3] Id.

[4] Zakai Zeigler drops bid to play 5^th college season, but his lawsuit against NCAA will continue, Associated Press (Jul. 1, 2025), https://apnews.com/article/tennessee-zakai-zeigler-lawsuit-pistons-323876e4b82844a68da27362a1d102da

[5] Philip T. Sheng and Rachel Kipp, Ziegler v. NCAA: Four-Seasons Rule Under Antitrust Scrutiny, Venable LLP (May 23, 2025), https://www.venable.com/insights/publications/2025/05/zeigler-v-ncaa-four-seasons-rule-again-under

[6] Id.

[7] Jordan Mendoza, College athlete files lawsuit against NCAA challenging redshirt rule, USA Today (Sep. 2, 2025), https://www.usatoday.com/story/sports/ncaaf/2025/09/02/college-athletes-ncaa-lawsuit-redshirt-rule/85948425007/

[8] Id.

[9] Id.

[10] Id.

[11] Id.

[12] Id.

[13] Id.

[14] Id.

[15] Judge denies Ziegler’s request for preliminary injunction trying to play a 5^th season, Associated Press (June 12, 2025), https://apnews.com/article/ncaa-tennessee-zakai-zeigler-lawsuit-808bf62c58c0f1ac0713a337a2d4ec72

[16] Dan Murphy, College athletes suing NCAA to extend eligibility to 5 seasons, ESPN (Sep. 2, 2025), https://www.espn.com/college-football/story/_/id/46141528/two-vanderbilt-players-suing-ncaa-extend-eligibility

[17] Id.