Joey Aguilar’s Dismissal From Diego Pavia Lawsuit: Injunction Denied

Joey Aguilar’s lawsuit against the NCAA ended on February 20, 2026, when a Knox County chancellor denied his request for a preliminary injunction and dissolved the temporary restraining order that had briefly returned him to Tennessee’s football team. The ruling closed his college career after he had already dropped out of quarterback Diego Pavia’s federal antitrust case to chase faster relief in Tennessee state court. He went undrafted in the 2026 NFL Draft and signed with the Jacksonville Jaguars.¹

The Eligibility Problem Behind the Suit

NCAA Division I rules give athletes a five-calendar-year window to play four seasons, and the clock starts the moment a student enrolls full-time at any college, junior colleges included.² Aguilar’s two seasons at Diablo Valley Community College counted against both totals, so after his 2025 season at Tennessee the NCAA considered him done. He saw it differently: only three of his seasons had been at NCAA schools, and he argued the junior college years should not have burned NCAA eligibility.

He was able to play the 2025 season at Tennessee only because of a blanket one-year waiver the NCAA issued in December 2024 for former JUCO athletes who would otherwise have been out of eligibility. That waiver applied to the 2025–26 academic year alone and did not extend anyone’s five-year clock.³ To play in 2026, Aguilar needed a court order.

Joining and Leaving the Pavia Federal Case

On November 21, 2025, Aguilar was added as a plaintiff to Pavia’s federal antitrust lawsuit against the NCAA through an amended complaint filed in the U.S. District Court for the Middle District of Tennessee. He joined more than two dozen other former JUCO players represented by attorney Ryan Downton, whose strategy aimed to turn the case into a class action and permanently strike down the rule counting JUCO seasons toward NCAA eligibility.⁴

That case moved too slowly for a quarterback with spring practice approaching and the NFL Draft on the calendar. A preliminary injunction hearing in the Pavia matter was set for February 10, 2026, with a trial not until February 2027. On January 30, 2026, a court granted Aguilar’s voluntary dismissal from the federal case. The plan, according to reporting at the time, was to seek a temporary restraining order in Tennessee state court, where he was thought to have a better chance of fast relief.⁵ For the state-court case, Aguilar retained attorney Cam Norris, who had previously won an NCAA-related case for Tennessee and player Nico Iamaleava.⁶

The Knox County Lawsuit and the Temporary Restraining Order

Aguilar sued the NCAA in the Knox County Chancery Court in Knoxville, citing Tennessee state antitrust laws and seeking declaratory and injunctive relief to play for Tennessee in 2026.⁷ The complaint argued that the NCAA “arbitrarily counts the years he played in junior college, at a non-NCAA school, as years he played in the NCAA,” and that shutting him out of a fourth Division I season deprived both him and Tennessee of millions of dollars in compensation.⁶

On February 4, 2026, a Knox County judge granted a 15-day temporary restraining order preventing the NCAA from restricting his eligibility and letting him rejoin the team on a short-term basis.⁸ A preliminary injunction hearing, which would decide whether he could play the full 2026 season, was set for February 13.

Why the Chancellor Denied the Injunction

At the February 13 hearing, Norris kept the ask narrow, telling Chancellor Christopher Heagerty that “the only relief that we’ve asked for, is for Mr. Aguilar to be able to play in 2026,” and framing a lost college season as a “priceless experience” that money could not repair.⁹ Heagerty took the matter under advisement.

A week later, on February 20, 2026, he denied the injunction and dissolved the TRO. The ruling rested on four points:

Aguilar was unlikely to succeed on the merits. The court found he had not shown that the NCAA’s JUCO rule had a “substantial effect” on Tennessee trade or commerce, as the Tennessee Trade Practices Act requires. His evidence pointed to his own lost NIL income rather than broader economic harm to Tennessee consumers or the state economy.¹⁰
The dormant Commerce Clause blocked the state-law theory. Because the NCAA’s eligibility rules substantially affect interstate commerce, using a Tennessee antitrust statute to override them would impose an “impermissible burden on interstate commerce.”¹⁰
Tennessee’s NIL statute gave him no private right to sue. Aguilar cited Tenn. Code Ann. § 49-7-2803, but the court held the statute does not create a private cause of action or authorize private injunctive relief, and that enforcement is reserved to the Tennessee Attorney General.¹⁰
The implications would not stay narrow. Despite Norris’s framing, Heagerty reasoned that a favorable ruling would produce “significant ambiguity and uncertainty regarding the eligibility rules of the NCAA,” because other athletes in similar positions would follow the same path.¹¹

Heagerty accepted that Aguilar faced irreparable harm in the form of lost eligibility and NIL income, but concluded the balance of harms was “only equal at best,” not enough to overcome the failure to show a sufficient likelihood of success, which the court called “typically determinative” for injunctive relief.¹⁰

Why Pavia and Chambliss Won and Aguilar Did Not

The gap between Aguilar’s loss and two contemporaneous wins came down to venue and legal theory.

Pavia had sued in federal court under Section 1 of the Sherman Antitrust Act, and on December 18, 2024, Chief U.S. District Judge William L. Campbell Jr. granted him a preliminary injunction, finding a “substantial anticompetitive effect in the labor market” and drawing on the Supreme Court’s 2021 decision in NCAA v. Alston to hold that eligibility rules in the NIL era are “commercial in nature” and subject to antitrust scrutiny.¹² Federal antitrust law carries none of the interstate commerce limits that sank the Tennessee state-law claim.

Ole Miss quarterback Trinidad Chambliss went a third way. He sued in Mississippi state court but did not attack the JUCO rule at all. Instead he argued that the NCAA breached its contractual obligation to apply its own bylaws in good faith when it denied his medical hardship waiver for a season he missed at Ferris State due to chronic tonsillitis.¹³ A Mississippi judge granted his preliminary injunction on February 12, 2026, focusing on procedural irregularities in the NCAA’s waiver process rather than on any attempt to rewrite national rules.¹⁴

Aguilar’s case fell between those two lanes. He filed in state court but leaned on state antitrust law to challenge a national rule, a combination the chancellor found constitutionally untenable. His theory was broader than the contract-based argument Chambliss used and lacked the federal statutory footing that carried Pavia.

What Happened After the Ruling

With his college career over, Aguilar turned to the NFL. He attended the Scouting Combine in Indianapolis days after the ruling but did not throw while recovering from January surgery to remove a benign tumor in his throwing arm. He threw later at Tennessee’s Pro Day, went undrafted in the 2026 NFL Draft, and signed with the Jacksonville Jaguars as an undrafted free agent.¹

The larger fight he tried to join goes on without him. Judge Campbell set a trial date in the Pavia case for February 2027, with the plaintiffs seeking to permanently abolish the rule that counts JUCO seasons against NCAA eligibility.¹⁵ A win there would vindicate the principle Aguilar argued for in Knoxville, just not in time to put him back on the field.

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NIL Revolution. Eligibility After Alston: Why Pavia and Chambliss Won and Aguilar Didn’t
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Law360. Trial Date for Pavia’s NCAA Eligibility Suit Set for Feb 2027