The Patterson v. NCAA lawsuit is a federal antitrust class action that asks the courts to strike down the NCAA’s four-season eligibility cap and let Division I athletes compete in all five years of their eligibility window. Filed in September 2025 by ten current and former college athletes, the case argues that the so-called redshirt rule is an illegal restraint of trade under the Sherman Antitrust Act. The lead plaintiff is Vanderbilt linebacker Langston Patterson, and the sole defendant is the NCAA.
The plaintiffs’ proposed fix is straightforward. Their attorney, Ryan Downton, summed it up this way: “Five years to practice, five years to graduate, five years to play.”
The Redshirt Rule the Case Targets
Under current NCAA rules, Division I athletes have five years from initial enrollment to use four seasons of competition. An athlete who sits out a year — because of injury, coaching decisions, academics, or choice — is said to redshirt, preserving one of the four playing seasons for later. During a redshirt year the athlete can still practice, keep a scholarship, and sign NIL deals. Games are the only thing off-limits.
Football has one carve-out, added in 2018: a player can appear in up to four regular-season games (plus postseason) without burning a season. Every other sport treats a single game appearance as a full season used.
The practical result is that a freshman who plays enough early games has only three full seasons left, with one year on the sideline. Patterson argues that tradeoff has become economically damaging now that athletes can earn NIL money and, under the recently approved House v. NCAA settlement, share directly in institutional revenue.
Where the Case Was Filed and Who’s Involved
The complaint was filed on September 2, 2025, in the U.S. District Court for the Middle District of Tennessee in Nashville, docketed as case number 3:25-cv-00994. It was assigned to Chief Judge William L. Campbell Jr., with Magistrate Judge Alistair E. Newbern handling pretrial matters.
The original ten named plaintiffs come from multiple schools and sports, including Vanderbilt, the University of Hawaii, Missouri, Central Michigan, Santa Clara, Long Beach State, and the University of Texas. One plaintiff, Vanderbilt defensive lineman Yilanan “Issa” Ouattara, voluntarily dismissed his individual claims in November 2025 for reasons not publicly documented. Ryan Downton represents the athletes.
The Antitrust Argument
The lawsuit alleges the four-season cap violates Section 1 of the Sherman Antitrust Act, the same provision the Supreme Court applied to NCAA compensation rules in its 2021 Alston decision. The theory is that NCAA member schools have collectively agreed to limit how long athletes can compete, which the plaintiffs describe as a horizontal restraint among competitors in the labor market for Division I athletes.
The plaintiffs argue this cap suppresses market output by sidelining athletes who could otherwise be competing and earning. A forced sit-out year costs an athlete not just games but NIL income and any share of the revenue distributions now permitted under the House settlement.
They also point to less restrictive alternatives the NCAA could adopt, such as tying eligibility to existing academic benchmarks like credit hours and GPA rather than counting competitive seasons. The complaint notes the NCAA has repeatedly carved exceptions into the rule — the 2018 football exception, the COVID-era blanket waiver granting extra seasons, and the 2023 elimination of the transfer sit-out requirement — which plaintiffs say undercuts the argument that the four-season limit is necessary.
How the NCAA Is Defending the Rule
The NCAA argues the eligibility limits promote academic progress by tying athletic participation to a normal graduation timeline. It contends the rules preserve competitive balance by keeping experienced athletes from indefinitely blocking roster spots for younger players. And it maintains that its eligibility framework falls outside commercial antitrust scrutiny because the rules govern participation, not compensation.
The association has also taken the position, consistent with its stance in other suits, that changes to eligibility should come from Congress rather than the courts. In a statement after the filing, the NCAA said its eligibility rules “enable student-athletes to access the life-changing opportunity to be a student-athlete” and are “widely supported” across member institutions.
The Preliminary Injunction Was Denied
In November 2025, five plaintiffs asked for a preliminary injunction that would let them personally compete in the 2026-27 season while the case continued. The five were Patterson, Wisconsin kicker Nathanial Vakos, Wisconsin long snapper Nick Levy, Wisconsin tight end Lance Mason, and Nebraska long snapper Kevin Gallic. Judge Campbell held a hearing on December 15, 2025.
On January 15, 2026, the court denied the motion. Judge Campbell acknowledged the athletes had shown some irreparable harm, recognizing that a lost season cannot be restored. But he concluded they had not shown a likelihood of success on the Sherman Act claim at that early stage, finding insufficient evidence of market harm on the limited record and holding that the plaintiffs had not adequately rebutted the NCAA’s procompetitive rationale.
The court also weighed the balance of equities against the plaintiffs, citing the administrative and competitive disruption that would follow from ordering a major rule change through a preliminary order. The NCAA argued that centralized, uniform eligibility rules are essential given what it called a “patchwork of state laws and inconsistent, conflicting court decisions” already affecting college sports.
One question the court explicitly left for later was whether the class-action release in the House settlement bars the Patterson claims outright. Judge Campbell said that issue needs further briefing.
Downton accepted the reasoning while signaling the fight continues. “We understand why the court did not want to require such a major rule change on a limited judicial record,” he said, adding that the NCAA has no “legitimate reason to make athletes sit out most (or all) of one of their five seasons of eligibility.”
Why an Earlier Eligibility Case Came Out the Other Way
Judge Campbell handled a related but narrower challenge in December 2024, when he granted a preliminary injunction to Vanderbilt quarterback Diego Pavia. Pavia challenged the NCAA rule counting junior-college seasons toward Division I eligibility limits. The judge found that rule was likely a restraint on trade with substantial anticompetitive effects, called the NCAA’s academic-progress justification “pretextual,” and blocked the NCAA from punishing Vanderbilt for playing him. The NCAA appealed but then issued a blanket waiver for all athletes in Pavia’s position, mooting the appeal. The Sixth Circuit dismissed the appeal in October 2025 and refused to vacate the injunction, since the NCAA itself had caused the mootness.
The difference between the two cases appears to be scope. Pavia challenged a specific rule affecting a discrete group of athletes. Patterson asks the court to overhaul the foundational four-season structure for every Division I athlete, an intervention the court was unwilling to order on a preliminary basis.
Who Would Benefit if the Plaintiffs Win
The lawsuit seeks certification of two classes. The first would include Division I athletes who enrolled beginning in fall 2022 and either have not yet used a redshirt year or retain eligibility for the 2026-27 academic year. The second, called the “Lost Opportunities Damages Class,” would cover athletes who enrolled between fall 2020 and spring 2022, did not use a redshirt year, and exhausted their four seasons by the end of 2024 or 2025. The plaintiffs estimate the combined classes could include thousands of athletes.
Where the Case Stands
As of mid-2026 the case remains active in Judge Campbell’s court, with the most recent docket filing recorded in May 2026. No class certification ruling, trial date, or settlement discussion has been publicly reported.
Patterson is separate from the compensation-focused lawsuits reshaping college athletics. The House v. NCAA settlement, approved on June 6, 2025, authorizes schools to share revenue directly with athletes and creates a $2.8 billion back-damages fund. Patterson does not challenge those payment rules. It challenges only the ceiling on how many seasons an athlete may play.