Judge denies preliminary injunction in Patterson v. NCAA eligibility lawsuit

The NCAA picked up a legal victory Thursday in a key eligibility lawsuit. A Tennessee judge denied a preliminary injunction in the Patterson v. NCAA case.

Judge William Campbell issued the decision Thursday afternoon in the U.S. District Court for the Middle District of Tennessee. Vanderbilt linebacker Langston Patterson led a group of athletes who sought to challenge the “five-year rule” as they sought another season of eligibility in 2026-27.

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In the ruling, Campbell argued the plaintiffs, “have not shown the procompetitive benefits can be achieved through substantially less restrictive means,” according to the filing. That was part of the reasoning behind the denial. Campbell also made the landmark ruling in favor of a preliminary injunction for Diego Pavia in late 2024.

“Plaintiffs are correct that their proposed alternative that allows non-Redshirt student- athletes an additional year of eligibility is less restrictive, but so too is any increased time on eligibility,” the filing states. “When considering such deviations, the Court must be especially mindful of its own limitations and not second guess degrees of efficiency. Does four years of competition strike a perfect competitive balance? Maybe it does. Maybe it does not.

“Based on the current record, the Court cannot accurately compare and contrast the market effects of a four-year versus a five- or six- or seven-year time limit with and without Redshirt exceptions. And even if that analysis could be performed accurately, unless it showed that the restrictions are patently stricter than necessary, i.e., that the same benefits can be achieved through substantially less restrictive means, a finding that a four-year limit on eligibility to compete violates antitrust laws would not be warranted.”

Thursday’s ruling marks a legal victory for the NCAA. The association has largely been on the right side of eligibility lawsuits, and the Patterson case loomed as a big one as plaintiffs sought to eventually secure a blanket five years of eligibility for all athletes. All told, the NCAA has now won 26 of 36 eligibility cases in which a judge made an injunction decision, according to Ross Dellenger.

It’s also separate from the Pavia suit, which is still ongoing. The last update in that case came late last month when attorneys cited the NCAA’s decision to grant James Nnaji, a former NBA Draft pick, four years of immediate eligibility. Nnaji signed with Baylor and made his debut earlier this month.

In addition, Pavia’s lawyers are seeking to file another amended complaint while adding more plaintiffs. The suit still does not have class-action status, meaning it would only impact plaintiffs listed. Tennessee quarterback Joey Aguilar joined as a plaintiff in December.