Diego Pavia Lawsuit, Federal Judge Denies Redshirt Extension, But JUCO Fight Continues for 2026 Eligibility 2026
On January 15, 2026, U.S. District Judge William L. Campbell Jr. denied a preliminary injunction sought by Vanderbilt linebacker Langston Patterson and four other athletes challenging the NCAA’s redshirt rules. While this setback affects the “five for five” case, Diego Pavia continues to pursue another year of college football through a separate lawsuit arguing that former JUCO players are unfairly restricted compared to other categories of athletes. The Heisman Trophy runner-up’s legal battle could reshape college sports eligibility forever, even though he’s declared for the 2026 NFL Draft.
What the Diego Pavia Lawsuit Is About
Diego Pavia sued the NCAA under the Sherman Antitrust Act, claiming that the NCAA’s decision to include his time at New Mexico Military Institute, a JUCO school, when assessing his playing eligibility unjustifiably limited his ability to profit off of his name, image, and likeness. The case centers on whether counting junior college seasons violates federal competition law.
Pavia started playing at New Mexico Military Institute in 2020; the NCAA did not count that season toward eligibility because of the COVID-19 pandemic. He led the junior college to the 2021 national championship then played at New Mexico State in 2022 and 2023 before transferring to Vanderbilt for 2024.
This made 2025 his sixth year in college football but only his fourth at the Division I level. Understanding how antitrust lawsuit like happend in ticketmaster-faces-billion-dollar-reckoning claims work helps explain why Pavia’s legal team believes NCAA rules violate federal law.
Legal Claims Filed Against the NCAA
The lawsuit claims the NCAA’s rules unfairly restrict former JUCO players’ access to earnings through NIL deals and revenue sharing, while allowing other older or nontraditional athletes more flexibility. Pavia’s attorneys argue Division I college football operates as a labor market where athletes compete for compensation opportunities.
The filing cites examples such as postgraduate prep school players, athletes who previously played other professional sports, and recent NCAA decisions allowing former professional basketball players to return to college competition. Attorney Ryan Downton seized on Baylor’s announcement that 7-foot center James Nnaji had joined the Bears after four seasons playing professionally in Europe, including being drafted No. 31 overall by the Detroit Pistons.
Next came the expanded complaint. On December 27, 2025, Diego Pavia and 26 other former JUCO football players asked Chief U.S. District Judge William L. Campbell Jr. to issue a temporary restraining order and preliminary injunction that would block the NCAA from enforcing applicable eligibility rules pending a final judgment.
Court Rulings in 2025 and January 2026
Judge Campbell granted Pavia a preliminary injunction in December 2024, allowing him to play during the 2025 season—a ruling that helped spark a wave of similar lawsuits nationwide. Then the NCAA tried to appeal.
On October 1, 2025, a federal appeals panel dismissed the NCAA’s eligibility case against Pavia, who was playing under a preliminary injunction. Judge Amul R. Thapar noted Pavia won the preliminary injunction before the NCAA hurt its appeal by granting a waiver to athletes in his position.
The Sixth Circuit’s reasoning was clear. Thapar wrote that the NCAA gave Pavia exactly what he wanted—a waiver that guaranteed he could play for Vanderbilt in 2025, providing him complete relief at the preliminary-injunction stage. This made the appeal moot.
Then came a separate case with different results. On January 15, 2026, Judge Campbell denied a preliminary injunction sought by five athletes in a lawsuit brought by 19 plaintiffs challenging the NCAA’s redshirt rules. The plaintiffs, led by Vanderbilt linebacker Langston Patterson, were asking the court to allow a fifth season of competition within the standard five-year eligibility window.
Attorney Ryan Downton acknowledged the setback but emphasized that the fight is far from over, stating he understood why the court did not want to require such a major rule change on a limited judicial record.
Pavia Seeks 2026 Eligibility Despite NFL Plans
Pavia’s group desires for former JUCO football players to be able to compete in D-I without regard to years of eligibility or seasons of competition at junior colleges. No trial date has been set yet for Pavia v. NCAA, with the two sides suggesting trial dates to Campbell ranging from June 2026 to February 2027.
Here’s where it gets interesting. Pavia has publicly indicated he intends to participate in the 2026 NFL draft, with the NFL’s deadline for underclassmen to declare being January 14. But the lawsuit continues.
On September 16, 2025, Pavia’s lawyers argued that he should actually be eligible for the 2026 season as well, under the NCAA’s redshirt rules if his time in junior college doesn’t count towards eligibility. Their argument is that if the NCAA’s rules stipulate that five-year eligibility requires players to pursue a four-year degree during that time, when a player is in junior college pursuing a two-year degree, that should not count.
What Relief the Lawsuit Seeks
The group wants the court to block the NCAA from enforcing applicable eligibility rules pending final judgment, allowing former JUCO players to compete without regard to years spent at junior colleges. This would fundamentally change how the NCAA treats JUCO transfers.
The broader implications matter beyond individual players. If successful, thousands of current and future JUCO transfers could gain additional years of Division I eligibility and NIL earning opportunities. For context on how major antitrust lawsuit like pepsi-and-walmart cases reshape entire industries, similar legal theories have challenged corporate practices affecting millions of consumers.
What You Must Know
Understanding Sherman Antitrust Act Claims
The Sherman Antitrust Act prohibits agreements that restrain trade or competition. Pavia’s legal team argues NCAA eligibility rules function as restrictions on athletes’ ability to compete in the labor market for Division I football positions and NIL compensation.
Judge Whitney D. Hermandorfer’s concurrence stated that the NCAA cannot immunize any trade restraint from review by deeming it eligibility related, otherwise price-fixing in Alston could pass unscrutinized if recast as a rule rendering ineligible any player receiving excessive benefits. This signals courts view eligibility rules through an antitrust lens in the NIL era.
Legal Precedents Supporting Pavia’s Claims
Two landmark Supreme Court cases established that NCAA rules must survive antitrust scrutiny. In O’Bannon v. NCAA (2014), courts found the NCAA violated antitrust law by restricting compensation related to athletes’ names, images, and likenesses. Then came Alston v. NCAA (2021), where the Supreme Court unanimously ruled NCAA limits on education-related benefits violated antitrust law.
Downton pointed out that both the JUCO and redshirt rules are subject to United States Antitrust laws—a threshold issue in both the Pavia and Patterson cases. These precedents make it harder for the NCAA to defend eligibility restrictions as necessary for amateurism.
Why the January 2026 Redshirt Ruling Matters
Judge Campbell’s denial of the preliminary injunction in the Patterson redshirt case doesn’t directly affect Pavia’s JUCO lawsuit. The cases involve different legal theories and different plaintiffs, though both are represented by the same legal team.
Campbell’s decision means those athletes challenging redshirt rules will remain ineligible to compete in the 2026-27 season while their lawsuit continues. However, Pavia’s separate case arguing JUCO time shouldn’t count remains pending with its own timeline and arguments.
What to Do Next
Access Federal Court Documents
You can find official case filings through the federal court’s PACER system at pacer.gov. The case is Pavia v. NCAA in the United States District Court for the Middle District of Tennessee, with Chief U.S. District Judge William L. Campbell Jr. presiding. Court dockets include complaints, motions, judicial orders, and attorney filings from both sides.
Monitor NCAA Eligibility Litigation
The NCAA is facing several eligibility lawsuits, with Downton representing players in another lawsuit over the NCAA’s redshirt rule. Legal developments in one case often influence strategy and outcomes in related litigation. Following multiple cases provides context for understanding broader challenges to NCAA authority.
Understand NIL and Revenue Sharing Changes
The House settlement requires schools to share revenue directly with athletes starting in 2025-26. The House payments will only further support Pavia’s claims against the NCAA, as the SEC is a named defendant alongside the NCAA in House and must abide by its terms, requiring schools like Vanderbilt to pay athletes a portion of athletics revenue.
This commercial reality strengthens arguments that NCAA eligibility rules restrict competition in a labor market. Athletes interested in their rights should consult with sports law attorneys who understand NCAA compliance and federal antitrust principles.
When Legal Advice Helps
Current and prospective college athletes with JUCO backgrounds should understand how Pavia’s case might affect their eligibility options. Sports attorneys can explain whether you might benefit from blanket waivers or future court rulings. The National Collegiate Athletic Association maintains official records at NCAA.org, though consulting independent legal counsel provides the most reliable guidance for individual situations.
Frequently Asked Questions
What is the Diego Pavia lawsuit about?
Pavia sued the NCAA under the Sherman Antitrust Act, arguing that counting his junior college seasons against Division I eligibility unfairly restricts his ability to compete and earn NIL compensation compared to other athletes who receive broader eligibility windows.
Who are the defendants in this case?
The NCAA is the defendant in Pavia v. NCAA. Pavia and 26 other former JUCO football players are the plaintiffs seeking court orders blocking the NCAA from enforcing eligibility rules against former junior college athletes.
What happened with the Sixth Circuit appeal?
The Sixth Circuit dismissed the NCAA’s appeal as moot on October 1, 2025, because the NCAA granted Pavia a waiver that gave him exactly what the preliminary injunction provided—the right to play in 2025. The NCAA’s own action made the appeal pointless.
What is the current status in January 2026?
Two related but separate cases are proceeding. Judge Campbell denied a preliminary injunction for the Patterson redshirt case on January 15, 2026, but Pavia’s separate JUCO lawsuit remains pending with no trial date set yet. Trial dates range from June 2026 to February 2027.
What relief are the plaintiffs seeking?
The plaintiffs want former JUCO players to compete in Division I without regard to years of eligibility or seasons of competition at junior colleges. This would give JUCO transfers the same five-year eligibility clock as players who started at four-year schools.
Is Diego Pavia actually going to play in 2026?
Pavia denied intentions to play in 2026, stating this is his last year. However, his lawyers continue arguing for 2026 eligibility to establish legal precedent for future athletes, not because Pavia personally plans to use another year of eligibility.
How does this compare to other NCAA antitrust cases?
Pavia’s case builds on Alston and O’Bannon, where courts ruled NCAA restrictions violated antitrust law. Similar challenges are reshaping college athletics, from NIL rights to revenue sharing. To see how antitrust principles apply across different industries, explore our coverage of the RealPage lawsuit where algorithmic pricing faced antitrust scrutiny.
Last Updated: February 2, 2026
Disclaimer: This information is for educational purposes only and does not constitute legal advice.
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About the Author
Sarah Klein, JD, is a licensed attorney and legal content strategist with over 12 years of experience across civil, criminal, family, and regulatory law. At All About Lawyer, she covers a wide range of legal topics — from high-profile lawsuits and courtroom stories to state traffic laws and everyday legal questions — all with a focus on accuracy, clarity, and public understanding.
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