Clarifying Antitrust Requirements For NIL-Era Eligibility Challenges

In a decision issued on November 25, 2025, the United States Court of Appeals for the Third Circuit vacated a preliminary injunction that had allowed Rutgers University football player Jett Elad to participate in the 2025-2026 season despite an eligibility restriction imposed by the National Collegiate Athletic Association (NCAA). Elad previously competed one season at Ohio University, one season at Garden City Community College, and two seasons at the University of Nevada. Under the NCAA's “Five-Year Rule,” any season played at a junior college counts toward an athlete's maximum of four permissible seasons of competition within a five-year period. Although Elad participated in only three seasons at the Division I level, his participation at the junior college (JUCO) level rendered him ineligible according to the NCAA.