On September 18, 2025, the U.S. District Court for the District of Nevada issued a significant order in Martinson v. National Collegiate Athletic Association, granting a preliminary injunction against the NCAA’s enforcement of its “Five-Year Rule” as applied to junior college (JUCO) athletes. The Five-Year Rule restricts student-athletes who attended a JUCO to a maximum of two or three seasons of NCAA Division I competition, while those who enroll directly in Division I institutions are eligible for four seasons.
Prior to becoming a Division 1 defensive lineman for the University of Nevada, Las Vegas (UNLV) football team, Plaintiff Tatuo Martinson played two full seasons at a JUCO. After completing two seasons at UNLV, the NCAA declared Martinson ineligible to play in the 2025-26 season citing the Five-Year Rule. As a result of his ineligibility, Martinson lost a name/image/likeness (NIL) opportunity for a video game, and potentially his spot on the UNLV football team.
Martinson challenged the Five-Year Rule by bringing suit against the NCAA for violating Section 1 of the Sherman Antitrust Act and breach of contract. Martinson argued the rule constituted an undue restraint on trade and caused immediate and irreparable harm by disqualifying him from the upcoming football season and associated career opportunities.
In yet another win for student-athletes, the court found that the Five-Year Rule operates as a restraint imposed by the NCAA’s monopsony power over the labor market for competitive athletic football service. As a result, the rule harms competition by limiting the amount of time JUCO athletes can participate in the labor market and, by extension, their compensation.
In opposition to Martinson’s claims, the NCAA argued that there should be an antitrust exemption to its eligibility rules because the rules are “non-commercial” and therefore beyond the scope the Antitrust Act. The court squarely rejected the NCAA’s hail mary attempt. In its reasoning, the court relied heavily on the landmark decision in National Collegiate Athletic Ass’n v. Alston, 594 U.S. 69 (2021), which held that NCAA bylaws prohibiting compensation for student-athletes violated Section 1 of the Sherman Act. The court stated that post-Alston, the product offered by the NCAA—competitive college athletic sports—is now considered a labor market with compensated workers. The court reasoned it would be unjustifiable for the NCAA’s eligibility rules to be deemed “non-commercial” when those rules determine the ability of Division 1 athletes to participate, and thus be compensated, in the labor market offered by the NCAA. Additionally, the court found there was no dispute that the NCAA’s dominance over the labor market for student-athlete services was significant, especially post-Alston where 99% of NIL opportunities were given to NCAA Division I sports.
The court also refused to adopt the NCAA’s position that the Five-Year Rule has pro-competitive justifications. The court highlighted the NCAA’s lack of evidence to support its assertions and its prior inconsistent statements. Moreover, the court noted the goals of the NCAA could be accomplished through less restrictive means other than the Five-Year Rule.
This decision underscores the evolving legal landscape for college athletics, especially as direct compensation and NIL opportunities expand. Institutions should closely monitor ongoing antitrust challenges to NCAA eligibility rules, as further changes may affect student-athlete participation, scholarship awards, and compliance strategies.