In a significant ruling that adds another chapter to the ongoing legal battles over NCAA eligibility rules, the Eastern District of Tennessee has denied baseball player Alberto Osuna Sanchez’s request for a preliminary injunction against the NCAA’s junior college eligibility rule. This decision stands in contrast to several recent rulings that have chipped away at NCAA authority, offering important insights into how courts are evaluating eligibility challenges in the post-Alston era.
The Alberto Osuna Sanchez Case Explained
Alberto Osuna Sanchez, a talented college baseball player, began his career at Walters State (a junior college) before transferring to UNC Chapel Hill, where he played three seasons. When he sought to play a fourth season of Division I baseball at the University of Tennessee, he ran into the NCAA’s “JUCO Rule” (Bylaw 12.02.6), which counts seasons at junior colleges against an athlete’s four years of Division I eligibility.
Unlike Vanderbilt quarterback Diego Pavia, who successfully obtained an injunction against this same rule in December 2024, Osuna Sanchez’s request was denied. This is the same result, but for different reasons, as the recent denial of Dylan Goldstein’s request for preliminary injunction against the NCAA. While the NCAA issued a blanket waiver following Pavia’s case, it only applied toathletes who attended and competed at a non-NCAA school for 1 or more years to remain eligible and compete in 2025-26 if those athletes would have otherwise used their final season of competition during the 2024-25 academic year, and meet all other eligibility requirements (e.g., progress toward degree, five-year period of eligibility).
Key Aspects of the Court’s Reasoning
Judge Charles Atchley’s opinion focuses primarily on antitrust analysis, finding that Osuna failed to demonstrate that the JUCO Rule produces “substantial anticompetitive effects” – a necessary element of his Sherman Act claim. The court concluded:
- Insufficient evidence of market harm – The limited record didn’t show that the JUCO Rule clearly dissuades athletes from attending junior colleges when many other factors influence this decision.
- Unconvincing consumer welfare argument – The court was not persuaded that the rule substantially harms the quality of competition by preventing former JUCO athletes from playing four full seasons at the Division I level.
- Possibility of pro-competitive effects – The court acknowledged the NCAA’s argument that by restricting the supply of athletes, the rule might actually increase competition among institutions and drive up athlete compensation.
- Undeveloped record – Unlike the landmark Alston case, which reached the Supreme Court after extensive fact-finding, this particular matter — a motion for preliminary injunction — was decided at a preliminary stage of litigation with limited evidence. Judge Atchley took a cautious approach, emphasizing that courts should not condemn NCAA rules after just a “quick look” unless they “so obviously” harm competition. The judge noted that “other courts have noted, when analyzing the rule of reason’s second step, that the NCAA’s procompetitive justifications for its rules often ring hollow.” However, without clear evidence of anticompetitive effects, the court declined to move to that analysis.
The Evolving Legal Landscape for NCAA Eligibility Rules
The Alberto Osuna Sanchez decision highlights a key tension in post-Alston jurisprudence: when are NCAA eligibility rules “commercial” and thus subject to antitrust scrutiny?
The court noted this unsettled question, stating: “the NIL era, in many ways, blurs the lines between clearly commercial rules and those eligibility rules once thought to be explicitly non-commercial.” While assuming for argument’s sake that the JUCO Rule is commercial, Judge Atchley’s opinion suggests some eligibility rules might still fall outside antitrust review.
What This Means for Athletes, Institutions, and the NCAA
This ruling offers several key takeaways:
- Geographical lottery for athletes – The location where an athlete files a lawsuit challenging NCAA rules may now significantly impact their chances of success, with courts taking divergent approaches.
- Tactical advantage to the NCAA – By arguing cases should be decided only after extensive factual development, the NCAA may be able to delay unfavorable rulings in some jurisdictions.
- NCAA reform pressure continues – While this ruling favors the NCAA, the court’s skeptical language about the organization’s justifications suggests the legal pressure will continue.
- Legislative solution needed? – The growing patchwork of rulings may increase pressure for federal legislation to establish consistent standards for college athletics.
The Court’s Final Assessment
Perhaps most tellingly, Judge Atchley concluded with this striking observation:
“The Court is sympathetic to Plaintiff’s position. For an organization that professes to prioritize the well-being of its student-athletes, the NCAA’s conduct has in many ways been questionable at best and self-interested at worst. Still, Plaintiff’s extraordinary talents cannot alone justify the extraordinary remedy he seeks.”
This language, despite ruling for the NCAA, indicates growing judicial impatience with the organization’s approach to athlete welfare.
As colleges and universities prepare for the 2025-26 academic year with the NCAA’s blanket waiver in effect for former JUCO athletes, the larger question remains: how long can the NCAA maintain its traditional eligibility framework in the rapidly evolving landscape of college sports?