The NCAA volunteer coach settlement is actually two related antitrust class settlements that together pay former Division I “volunteer” assistant coaches for years of unpaid work. Smart v. NCAA resolved the claims of Division I baseball coaches for $49.25 million, and Ray v. NCAA resolved the claims of volunteer coaches in every other Division I sport for $303 million. Both cases attacked the same NCAA bylaw, and both ended with final approval from the same federal judge in the Eastern District of California.
The Rule That Made the Cases Possible
From 1992 until July 1, 2023, NCAA Bylaw 11.01.06 let each Division I team designate one coach as a “volunteer.” Schools were barred from paying that person a salary or providing standard benefits such as health insurance, housing, or retirement contributions.1OnLabor. Volunteer Assistant NCAA Coaches: Can Antitrust Law Help Employees Recover When They Weren’t Compensated The label did not match the job. Volunteer coaches routinely worked more than 40 hours a week running practices, planning strategy, traveling with teams, and coaching games. Some picked up under $15,000 a year from team-run camps or clinics, but nothing from the athletic department itself.2Washington Journal of Law, Technology & Arts. Former Unpaid Volunteer College Coaches Seek Millions of Dollars From the NCAA
The plaintiffs’ antitrust theory was that hundreds of Division I schools had agreed, through the bylaw, to fix the price of this labor at zero. In a competitive market, they argued, schools would have bid against one another and paid real salaries. Judge William B. Shubb, who heard both cases, found that argument plausible enough to move forward. The NCAA Division I Council itself voted in January 2023 to eliminate the volunteer designation effective July 1, 2023, converting those roles into paid “countable coach” positions.3NCAA. NCAA Division I Council Modernizes Rules on Coaching Limits
Smart v. NCAA: The $49.25 Million Baseball Settlement
Taylor Smart and Michael Hacker led the baseball case, filed in November 2022 in the Eastern District of California as Case No. 2:22-cv-02125.4Justia. Smart v. National Collegiate Athletic Association, No. 2:22-cv-02125 They sued under Section 1 of the Sherman Act, alleging horizontal price-fixing of coaching wages.
The settlement class covers anyone who served as a Division I volunteer baseball coach between November 29, 2018, and July 1, 2023. Class members were included automatically unless they opted out by July 14, 2025.5Volunteer Baseball Coach Settlement. Frequently Asked Questions
The parties agreed in principle on January 31, 2025, for $49.25 million. Lead counsel Garrett Broshuis of Korein Tillery said the figure represented “over 90% of the alleged damages,” with class members expected to average close to $50,000 apiece. Actual amounts vary by school and by the number of years the coach worked during the class period.6Korein Tillery. Korein Tillery Secures $49.25 Settlement for College Baseball Coaches Class counsel sought $14.775 million in fees, the 30 percent maximum allowed by the settlement agreement. Judge Shubb held the final fairness hearing on September 15, 2025, and signed final approval the next day.7Legal Newsline. Lawyers Seek $15M of $49M NCAA Volunteer Baseball Coach Settlement
Ray v. NCAA: The $303 Million Settlement for All Other Sports
Volunteer coaches in every other Division I sport pursued a parallel case. Originally filed in March 2023 as Colon v. NCAA and later known as Ray v. NCAA, it covered 7,718 people who served as volunteer coaches in non-baseball Division I sports between March 17, 2019, and June 30, 2023.8ESPN. Judge Gives Final Approval to Settlement for Ex-Volunteer Assistants in Class Action Lawsuit vs. NCAA The named class representatives were Shannon Ray, Khala Taylor, Peter Robinson, Rudy Barajas, and Katherine Sebbane, and the case was again assigned to Judge Shubb, who denied the NCAA’s motion to dismiss in July 2023.9NCAA Volunteer Coach Lawsuit. Ray v. NCAA Long Form Notice
On November 10, 2025, the parties settled for $303 million. Plaintiffs’ experts had estimated aggregate lost wages at $253.9 million and roughly $299.6 million when lost health benefits were added in, so the settlement covered about 101 percent of estimated damages. Judge Shubb granted final approval on May 11, 2026.10Sportico. Volunteer Coaches Antitrust Settlement NCAA Final Approval
Of the $303 million, $208.4 million goes to the coaches, $90.9 million to attorneys’ fees, and $3.6 million to costs and expenses. The five class representatives each received $25,000 service awards. Individual payouts are calculated from the coach’s school, sport, and years worked, benchmarked against what the lowest-paid non-volunteer coach on the same team actually earned. Eligible coaches were expected to average roughly $27,000, with a guaranteed minimum of $5,000. The money is paid in three equal installments across two calendar years, with the first payment expected no earlier than August 15, 2026.11Class Action. Ray et al. v. NCAA Notice
Who Qualifies and How Payments Are Calculated
Eligibility comes down to three questions: which sport, which years, and whether you opted out.
- Baseball coaches: you are in the Smart class if you served as a Division I volunteer baseball coach between November 29, 2018, and July 1, 2023. The opt-out deadline was July 14, 2025.
- All other Division I sports: you are in the Ray class if you served as a volunteer coach in any non-baseball Division I sport between March 17, 2019, and June 30, 2023.
Amounts are not flat. In both cases, individual payments turn on where you coached, the sport, and how many years of the class period you served. The Ray formula explicitly benchmarks each coach’s award against the pay of the lowest-paid non-volunteer coach on the same team, which is why payouts vary widely from person to person. Guaranteed minimums and averages are the settlement’s own figures; your check depends on your record.
How These Cases Fit Into the NCAA Antitrust Wave
The volunteer coach settlements are separate from House v. NCAA, the $2.8 billion name, image, and likeness settlement approved by Judge Claudia Wilken on June 6, 2025. House pays athletes, not coaches, and it created a new revenue-sharing framework and the College Sports Commission for schools going forward.12ESPN. Judge Grants Final Approval of House v. NCAA Settlement If you coached rather than played, House is not your case; Smart or Ray is.
The antitrust theory used in both coach cases was not new. In the late 1990s, the Tenth Circuit struck down the NCAA’s “restricted earnings coach” rule, which had capped certain entry-level coaching salaries at $16,000 a year, holding in Law v. NCAA that NCAA rules governing coach pay are subject to Sherman Act scrutiny.13FindLaw. Law v. National Collegiate Athletic Association The volunteer coach settlements applied that same principle to a rule that had capped pay not at $16,000 but at zero, for more than three decades, across every Division I sport.