The Ninth Circuit Court of Appeals has dismissed the NCAA's appeal concerning college football players' eligibility. The court ruled that the case was moot, as the players had already completed their collegiate careers. This decision affects the NCAA's ability to enforce its eligibility rules in similar situations in the future.
The case, Martinson v. National Collegiate Athletic Association, was filed under docket number 25-5962. It involved two college football players, Cortez Braham and Tatuo Martinson, who sought to challenge the NCAA's Five-Year Rule. This rule limits student-athletes to four seasons of competition within a five-year period, including time spent at junior colleges.
Braham and Martinson began their college football careers in 2019 at junior colleges before transferring to NCAA Division I schools. In the summer of 2025, they filed separate lawsuits against the NCAA, arguing that the Five-Year Rule was anticompetitive under Section 1 of the Sherman Act. They requested preliminary injunctions to allow them to play in the 2025 season, which they argued was a violation of their rights.
Both district courts granted the players' requests for preliminary injunctions, allowing them to compete in the 2025 college football season. However, after the season concluded, the players moved to dismiss the NCAA's appeals as moot, as the injunctions had expired and their collegiate eligibility had ended.
The court ruled that the appeals were moot because no effective relief could be granted to the NCAA. The judges noted, "Because these injunctions have already expired and these players’ collegiate careers are over, no effective relief can be granted to the NCAA." The panel included Circuit Judges Mark J. Bennett and Gabriel P. Sanchez, along with District Judge David A. Ezra, who sat by designation.
The court further explained that the NCAA failed to meet its burden to demonstrate that the mootness exception for controversies capable of repetition yet evading review should apply. The NCAA argued that the injunctions continued to bar it from enforcing the Rule of Restitution against the colleges where the players competed. However, the court disagreed, stating that the players' alleged antitrust injuries had ended with the conclusion of the season.
The Ninth Circuit's ruling means that the NCAA cannot pursue its appeal, and the players' ability to challenge the Five-Year Rule remains intact. This decision may set a precedent for future cases involving college athletes and their eligibility rights. The court emphasized that the capable-of-repetition doctrine applies only in exceptional situations, particularly when the named plaintiffs can demonstrate a reasonable expectation of facing the same action again.
Looking ahead, the NCAA may not be able to appeal this ruling, as the court has dismissed the case as moot. However, there may be related cases pending involving other student-athletes who could challenge the NCAA's eligibility rules in the future. The outcome of those cases could further shape the landscape of college athletics and the rights of student-athletes.