Four former junior college football players—Jimmori Robinson, Jeffrey Weimer, Tye Edwards, and Justin Harrington—challenged the NCAA's Five-Year Rule, which counts time spent at junior colleges toward student-athletes' seasons and years of NCAA eligibility. The rule rendered them ineligible for the 2025-26 collegiate football season at West Virginia University despite the NCAA's partial Pavia waiver that only addressed the four-seasons-of-competition component, not the five-year eligibility limit.
Senior Circuit Judge Henry F. Floyd wrote that the lower court erred by applying abbreviated 'quick-look' analysis instead of full rule-of-reason scrutiny and failed to properly define the relevant market. 'The district court clearly erred by failing to make any factual findings regarding the market,' Floyd wrote, criticizing the court for merely adopting the players' proposed 'nationwide market for the labor of NCAA Division I college football players' without supporting evidence.
The players filed suit in August 2025 alleging Sherman Act violations and seeking injunctive relief. U.S. District Judge John Preston Bailey granted their preliminary injunction on August 20, 2025, allowing them to play during the 2025-26 season. The NCAA appealed under 28 U.S.C. § 1292(a)(1), and the Fourth Circuit found the case wasn't moot under the 'capable of repetition, yet evading review' exception since college football seasons are too brief for full litigation.
The decision provides guidance for similar challenges nationwide as courts grapple with NCAA eligibility rules in the post-Alston era of name, image, and likeness compensation. The Fourth Circuit remanded for further proceedings, leaving open the possibility that players could succeed 'on a fuller record' but emphasized they failed to meet their evidentiary burden for preliminary relief.