By Olivia Rychlak
Six years ago, college football players would routinely forego their remaining years of collegiate eligibility if they were poised to be an early NFL draft pick. Before the name, image, and likeness (“NIL”) era, remaining in college rarely made financial sense. This dynamic has changed dramatically, as highlighted by two recent state court injunction hearings involving starting Southeastern Conference quarterbacks: Ole Miss’s Trinidad Chambliss and Tennessee’s Joey Aguilar.[1]
In NCAA v. Alston, the Supreme Court held that the National Collegiate Athletic Association’s (“NCAA”) rules limiting education-related benefits violated § 1 of the Sherman Antitrust Act, and the NCAA thereafter allowed student-athletes to receive compensation for their NIL.[2] More recently, the 2025 House settlement permitted universities to engage in direct revenue sharing with their athletes.[3] As a result, seeking an additional year of college eligibility can now carry meaningful financial value and is a rational economic decision for many athletes.[4]
On February 12, 2026, Ole Miss quarterback Trinidad Chambliss was granted a preliminary injunction by a Mississippi state court following the NCAA’s denial of his request for an additional year of eligibility.[5] Notably, Chambliss offered his claim under a breach of contract theory, arguing that the NCAA failed to apply its bylaws in good faith.[6] Specifically, Chambliss contended that a respiratory illness he suffered in 2022 while enrolled at Division II school Ferris State qualified him for a medical redshirt and therefore another year of eligibility.[7] The NCAA disagreed and upheld its denial on an internal appeal.[8]
A Mississippi judge, however, concluded that Chambliss satisfied the criteria to receive a medical redshirt, a ruling that went directly against the NCAA’s determination.[9] The court’s issuance of a preliminary injunction will allow Chambliss to compete during the upcoming season while the litigation proceeds, which will likely occur after the conclusion of the season.[10] Therefore, the injunction practically serves Chambliss the exact relief that he sought: the ability to play and financially capitalize on another year of Division I football.
Meanwhile, Tennessee quarterback Joey Aguilar was not as successful in his own state court challenge.[11] After the NCAA denied his waiver request, Aguilar sought similar injunctive relief in Tennessee state court.[12] Unlike Chambliss, however, he centered his argument on the claim that the NCAA was acting in violation of antitrust law, arguing that the NCAA improperly counted his junior college seasons against his Division I eligibility “clock.”[13] Aguilar’s argument mirrors those previously raised by Vanderbilt quarterback Diego Pavia, who contended that counting junior college participation against NCAA eligibility unfairly restricted his NIL opportunities.[14] Aguilar’s injunction was denied.
Although their outcomes differed, these cases underscore a growing trend of state-level courts as forums for challenging NCAA decision-making. Eligibility disputes now implicate not just competitive fairness, but also contract rights and economic opportunity worth millions of dollars.
Preliminary injunctions, in particular, have emerged as a powerful strategic tool.[15] Athletic seasons are short and time-sensitive, so a favorable ruling at the preliminary stage can, as a practical matter, resolve the dispute. Even if the NCAA eventually prevails on the merits, the athlete may have already competed and earned their desired financial benefits during the contested season.[16]
These cases illustrate a broader shift in the balance of power within college athletics, as state courts increasingly serve as venues to challenge the NCAA’s regulatory authority. The NCAA is no longer merely a centralized rule maker whose eligibility determinations are accepted as final. As college football continues its transformation into a multi-billion dollar enterprise, athletes will continue to mount creative challenges against the NCAA’s eligibility determinations in litigation.[17]
Olivia Rychlak is a 2L at Vanderbilt Law School from Oxford, Mississippi. She plans to pursue a litigation practice and is spending this coming summer at Troutman Pepper Locke in Houston.
[1] See Christopher Kamrani, Justin Williams, Ralph D. Russo, & Stewart Mandel, Questions and Answers About Trinidad Chambliss’, Joey Aguilar’s Eligibility Cases, N.Y. TIMES (Feb. 14, 2026), https://www.nytimes.com/athletic/7045406/2026/02/14/trinidad-chambliss-ole-miss-eligibility-joey-aguilar-tennessee/.
[2] See NCAA v. Alston, 135 Harv. L. Rev. 471 (2021); Nat’l Collegiate Athletic Ass’n v. Alston, 594 U.S. 69, 107 (2021).
[3] See Dan Murphy, Judge OK’s $2.8B Settlement, Paving Way for Colleges to Pay Athletes, ESPN (June 6, 2025, at 21:28 ET), https://www.espn.com/college-sports/story//id/45467505/judge-grants-final-approval-house-v-ncaa-settlement.
[4] See Kamrani et al. supra note 1 (noting that a third-round NFL draft pick may make around three million dollars, whereas Chambliss could bring in five to six million dollars at Ole Miss this season).
[5] See Shehan Jeyarajah, What’s Next for Ole Miss QB Trinidad Chambliss After Injunction Paves Way for Sixth Season of NCAA Eligibility, CBS Sports (Feb. 12, 2026, at 18:48 ET), https://www.cbssports.com/college-football/news/ole-miss-qb-trinidad-chambliss-injunction-sixth-season-ncaa-eligibility/.
[6] Philip T. Sheng & Parker G. Zimmerman, Chambliss v. NCAA: A Potential New Playbook for Future NCAA Eligibility Lawsuits, Venable LLP (Feb. 19, 2026), https://www.venable.com/insights/publications/2026/02/chambliss-v-ncaa-a-potential-new-playbook.
[7] See id.
[8] Id.
[9] Id.
[10] Id.
[11] See Ryan Dunleavy, Tennessee QB Joey Aguilar Learns 2026 Fate After Court Decision, N.Y. Post (Feb. 21, 2026, at 14:02 ET), https://nypost.com/2026/02/21/sports/tennessee-qb-joey-aguilar-learns-2026-fate-after-court-decision/.
[12] Id.
[13] See Adam Sparks, Why Judge Hasn’t Decided Joey Aguilar’s Eligibility for Tennessee vs NCAA, The Tennessean (Feb. 17, 2026, at 12:25 CT), https://www.tennessean.com/story/sports/college/university-of-tennessee/football/2026/02/17/joey-aguilar-eligibility-tennessee-football-ncaa-lawsuit-judge/88718628007/.
[14] Ralph D. Russo, Vanderbilt QB Diego Pavia Can’t Be Stopped. But What About His Court Battle with the NCAA?, N.Y. Times (Oct. 2, 2025), https://www.nytimes.com/athletic/6678418/2025/10/01/diego-pavia-lawsuit-juco-eligibility-vanderbilt/.
[15] See Dunleavy, supra note 11.
[16] See id.
[17] See The College Sports Litigation Tracker, https://www.collegesportslitigationtracker.com/ (last visited Feb. 23, 2026).