Riley Gaines Lawsuit: Title IX, 2025 Ruling, and Damages

The Riley Gaines lawsuit against the NCAA is a federal Title IX case filed on March 14, 2024, in the U.S. District Court for the Northern District of Georgia, challenging the NCAA’s former policy of allowing transgender women to compete in women’s collegiate athletics. Most of the original claims have been dismissed, but the core Title IX claim against the NCAA survived a September 2025 ruling and remains active as of mid-2026, with the case now turning on whether the NCAA counts as a federal funding recipient through its research partnership with the Department of Defense.

What Triggered the Case

The dispute traces back to the 2022 NCAA Women’s Swimming and Diving Championships in Atlanta. On March 18, 2022, Gaines, then a University of Kentucky swimmer, tied for fifth place in the 200-yard freestyle final with Lia Thomas, a transgender woman swimming for the University of Pennsylvania. NCAA officials handed the single fifth-place trophy to Thomas and told Gaines hers would be mailed. She was asked to hold the sixth-place trophy on the podium instead.¹

Gaines has said her objection was to the NCAA’s rules, not to Thomas: “She’s just abiding by the rules that the NCAA put in place, and that’s the issue.”¹ The complaint also raised concerns about female swimmers being required to share a locker room with Thomas at the championships without advance notice.²

Who Sued and What They Claimed

Gaines filed as lead plaintiff alongside nearly two dozen current and former female college athletes from swimming, track and field, volleyball, and tennis. Named plaintiffs include Reka Gyorgy, Kaitlynn Wheeler, Kylee Alons, Lillian Mullens, Kaitlin Blankinship, Ainsley Erzen, Kate Pearson, Elizabeth Satterfield, Ellie Eades, Julianna Morrow, and Susanna Price, with additional athletes proceeding under pseudonyms.³⁴

The complaint named three sets of defendants: the NCAA, the University System of Georgia (including members of its Board of Regents), and the Georgia Tech Athletic Association. It advanced three legal theories:

The NCAA’s transgender eligibility policies violated Title IX’s guarantee of equal educational opportunity for women.
Those policies violated the Fourteenth Amendment’s Equal Protection Clause.
Requiring female athletes to share locker rooms with transgender competitors violated their constitutional right to bodily privacy.⁴

The plaintiffs sought an injunction against the NCAA’s eligibility rules, a declaration that the policies were unlawful, monetary damages, and attorneys’ fees.⁵ Individual plaintiffs alleged concrete harms. Reka Gyorgy, a Virginia Tech swimmer and 2016 Olympian, finished 17th in the 500-yard freestyle at the 2022 championships and missed the finals by one place in her last collegiate meet.⁶

How the NCAA Is Defending Itself

The NCAA moved to dismiss on two main grounds. First, it argued that as a private nonprofit association it is not a state actor, so the Fourteenth Amendment claims should not reach it. Second, it argued that it does not receive federal financial assistance and therefore is not subject to Title IX, pointing to the Supreme Court’s 1999 decision in NCAA v. Smith, which held that collecting dues from federally funded member schools does not by itself make the NCAA a Title IX recipient.⁴ On the merits, the NCAA said its transgender participation rules aligned with federal guidance and reflected its commitment to fair competition in women’s sports.⁷

The September 2025 Ruling

On September 25, 2025, U.S. District Judge Tiffany R. Johnson, who took over the case from Judge Mark H. Cohen in January 2025, ruled on the motions to dismiss. Her decision cut the case down substantially but kept its most consequential theory alive.⁷

What Was Dismissed

All claims against the University System of Georgia and the Georgia Tech Athletic Association were dismissed. Judge Johnson found the plaintiffs’ injuries were not traceable to those defendants because they did not control NCAA eligibility decisions, and claims for forward-looking relief against the state entities were moot after Georgia enacted Senate Bill 1, the “Riley Gaines Act,” on April 28, 2025, banning biological males from women’s sports in the state.⁴⁸

The constitutional claims against the NCAA also fell. Relying on the Supreme Court’s 1988 decision in NCAA v. Tarkanian, Judge Johnson held the NCAA is not a state actor, so the Fourteenth Amendment claims and the bodily privacy claim did not apply to it. Claims against unnamed “John Doe” defendants were dismissed. Plaintiffs who had already graduated were found to lack standing for forward-looking relief, and the NCAA’s own February 2025 policy change made prospective claims speculative even for current athletes.⁴

What Survived

The Title IX claim against the NCAA remains. Judge Johnson found the plaintiffs had plausibly alleged that the NCAA directly receives federal financial assistance through its research partnership with the U.S. Department of Defense. The NCAA-DOD “Grand Alliance” CARE Consortium, launched around 2014 to study concussions in student-athletes and military service members, has involved over $105 million in combined investment according to the NCAA’s own figures.⁹ If the NCAA is a direct recipient of those funds rather than a pass-through, it could be subject to Title IX, a conclusion that would go beyond NCAA v. Smith.

The court ordered a 90-day period of limited discovery ending January 7, 2026, focused solely on the federal funding question, and required the NCAA to file its formal answer by October 9, 2025.⁷

Where the Case Stands Now

After discovery closed, the NCAA moved again to dismiss the remaining Title IX claim, asserting that the organization “never received federal funds” and is therefore outside Title IX’s reach. That motion was reported as pending in February 2026.¹⁰ The docket shows filings as recently as June 2026, no trial date has been set, and there is no public indication of settlement talks.³

The pivotal question is factual: did DOD funding flow to the NCAA in a way that makes it a Title IX “recipient”? A finding that it did would be the first to subject the NCAA to Title IX’s sex-discrimination provisions based on direct federal funding, with implications that could reach beyond transgender participation policies.

The NCAA’s Policy Change and Damages Claims

While the litigation was pending, the NCAA changed its own rules. On February 6, 2025, the Board of Governors announced an updated policy restricting women’s competition to student-athletes assigned female at birth, following a Trump administration executive order. Athletes assigned male at birth may practice with women’s teams and receive non-scholarship benefits but may not compete, and athletes assigned female at birth who have begun testosterone therapy are also barred from women’s competition. The policy took effect immediately.¹¹

That change is what Judge Johnson pointed to in finding the plaintiffs’ forward-looking injunctive claims largely moot. But the backward-looking damages claims, for harms the plaintiffs say they suffered under the old rules, remain live if the Title IX theory survives the NCAA’s latest motion.

1
Swimming World Magazine. Riley Gaines: I Left There With No Trophy After Tie With Lia Thomas
2
CNN. Riley Gaines, Lia Thomas, and UPenn
3
CourtListener. Gaines v. National Collegiate Athletic Association Docket
4
Civil Rights Litigation Clearinghouse. Gaines v. National Collegiate Athletic Association
5
ESPN. Swimmers, Other Athletes Sue NCAA Over Transgender Policies
6
Swimming World Magazine. Reka Gyorgy Writes Critical Letter to NCAA
7
USA Today. Riley Gaines Lawsuit: NCAA Title IX Claims Can Proceed
8
Office of the Lieutenant Governor of Georgia. Lt. Governor Burt Jones and Riley Gaines Comment on Senate Bill 1
9
NCAA. NCAA-DOD CARE Consortium
10
Law360. NCAA Looks to End Trans Athlete Eligibility Suit for Good
11
NCAA. NCAA Announces Transgender Student-Athlete Participation Policy Change