In a significant ruling that could impact numerous pending challenges to NCAA eligibility rules, the United States District Court for the Middle District of Georgia has denied a preliminary injunction sought by University of Georgia baseball player Dylan Goldstein, who had exhausted his NCAA eligibility but sought to play one additional season.
The Case: Goldstein v. NCAA
Goldstein, an accomplished college baseball player who began his career at Chipola College (JUCO) before playing at Florida Atlantic University and ultimately the University of Georgia, filed suit against the NCAA on February 18, 2025, challenging the organization’s “Seasons of Competition: Five-Year Rule” and “Five-Year Rule.” These bylaws limit college athletes to participating in no more than four seasons within five years.
The player’s eligibility expired on June 10, 2024, at the conclusion of the 2024 baseball season, after he had completed one COVID-exempt season, one JUCO season, and three Division I seasons. Goldstein’s lawsuit arose in response to the NCAA’s December 23, 2024 blanket waiver that extended eligibility only to former JUCO athletes who used their third year of Division I eligibility in the 2024-2025 academic year, allowing them to compete during the 2025-2026 season.
Goldstein argued that his exclusion from this waiver constituted an “arbitrary and anti-competitive” harm that created an “unlawful restriction on the market for Division I athletics” in violation of Section 1 of the Sherman Antitrust Act.
The Court’s Decision
In an opinion issued on February 28, 2025, Judge Tilman E. Self III denied Goldstein’s request for a preliminary injunction, providing reasoning that could shape how courts view similar challenges in the future.
The court’s decision rested on two key findings:
1. NCAA Eligibility Rules Are Non-Commercial and Not Subject to Antitrust Scrutiny
Judge Self distinguished between the NCAA’s compensation rules, which the Supreme Court struck down in NCAA v. Alston (2021), and the eligibility rules that Goldstein challenged. The court determined that Alston was “more scalpel than ax,” targeting only “a narrow subset of the NCAA’s compensation rules” rather than all NCAA regulations.
The court determined that the eligibility bylaws limiting the years athletes can play are “true ‘eligibility’ rule[s]” and not commercial in nature, therefore placing them outside the reach of antitrust scrutiny. Despite Goldstein’s attempts to connect these rules to potential Name, Image, and Likeness (NIL) earnings, the court was unconvinced that this transformed the eligibility rules into commercial restraints.
2. Insufficient Evidence for Rule-of-Reason Analysis
Even if the bylaws were subject to antitrust scrutiny, the court found that Goldstein failed to meet his burden of proving they had a substantial anticompetitive effect. Judge Self emphasized that defining the relevant market requires “almost necessarily an expert assessment,” which Goldstein did not provide.
The court noted: “Goldstein tendered no expert report, no economic analysis, or even a single exhibit that would allow the Court to conduct its required rule-of-reason analysis.” Without evidence demonstrating market-wide impact rather than just individual harm, the court could not find the anticompetitive effects necessary for an antitrust claim.
Implications for Pending NCAA Eligibility Challenges
This ruling has significant implications for the numerous pending lawsuits challenging the NCAA’s eligibility rules, particularly the five-year rule:
- Distinction Between Eligibility and Compensation Rules: The court reinforced a boundary between the NCAA’s commercially-oriented compensation rules (which Alston established are subject to antitrust scrutiny) and non-commercial eligibility rules (which may remain outside antitrust law’s reach).
- Evidentiary Burden in Antitrust Challenges: The court established a high evidentiary bar for athletes challenging eligibility rules, requiring expert testimony and economic analysis to define relevant markets and demonstrate anticompetitive effects.
- Continued Viability of O’Bannon: Judge Self explicitly found that O’Bannon v. NCAA remains good law for the proposition that eligibility rules are non-commercial in nature, despite Alston‘s impact on compensation rules.
- Requirement for Market-Wide Impact: The court emphasized that antitrust laws protect “competition, not competitors,” requiring evidence of market-wide anticompetitive effects rather than just individual harm.
While the Goldstein case specifically addressed a baseball player’s eligibility, the court’s reasoning would apply equally to football, basketball, and other NCAA sports where similar eligibility challenges are pending. The ruling signals that athletes challenging NCAA eligibility rules face an uphill battle unless they can:
- Prove the eligibility rules are commercial in nature;
- Provide expert testimony defining relevant markets; and
- Demonstrate anticompetitive effects beyond individual harm.
What’s Next?
The denial of the preliminary injunction is not the end of Goldstein’s case, which could still proceed to trial. However, the court’s finding that he is unlikely to succeed on the merits suggests an unfavorable outlook for the ultimate resolution of his claims.
For athletes with similar pending challenges, this ruling indicates they may need to substantially strengthen their evidence, particularly through expert economic testimony, or pursue alternative legal theories beyond antitrust law.
The decision also suggests that while Alston opened the door to antitrust scrutiny of some NCAA rules, courts remain hesitant to extend that scrutiny to all NCAA regulations, particularly those related to eligibility rather than compensation.
As college athletics continues to evolve in the post-Alston, NIL era, this ruling provides an important data point on where courts may draw the line between permissible NCAA governance and anticompetitive conduct.