I believe the court ruling, and then the ncaa announcement, only impacted this year, 2025. See the below linked article. The judge in this case seems to think that the issue raised for 2025 is probably still very much alive.
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The trial court granted him a preliminary injunction, blocking the NCAA from enforcing the JUCO Rule against him for the 2025 season and preventing it from punishing his current school under its restitution rule. That ruling ensured that Pavia could play in the short term. The NCAA appealed, hoping to reverse the injunction and reaffirm its control over eligibility rules. But before the Sixth Circuit could issue a decision, the NCAA announced a blanket waiver allowing all athletes in Pavia’s situation to play the 2025 season.
The Sixth Circuit ultimately dismissed the NCAA’s appeal as moot. Because Pavia already had the relief he sought — a guarantee to play in 2025 — the court concluded that no further ruling could provide “effectual relief” because what the NCAA was appealing was the
injunction — which it itself had effectively mooted by granting the blanket waiver. The court reasoned that regardless of the outcome of the NCAA’s appeal, Pavia would remain on the field for the 2025 season, and the restitution rule was irrelevant because he was not playing in violation of NCAA policy.
Although the ruling turned on mootness rather than the merits, the concurring opinions made clear that the legal questions at the heart of Pavia’s case remain very much alive. Judge Thapar emphasized the unsettled nature of antitrust law as applied to NCAA eligibility rules. He noted that courts have yet to fully examine whether rules like the JUCO Rule operate as unlawful restraints of trade, and he called for a more complete evidentiary record on market effects and justifications.
Judge Hermandorfer, meanwhile, focused on the real-world impact of the JUCO Rule in the labor market for Division I football players. He highlighted that excluding experienced JUCO players like Pavia from competition may depress overall wages and opportunities in a market where the NCAA already wields monopsony power.
Both opinions pointed to the broader uncertainty facing the NCAA in the wake of the Supreme Court’s decision in
National Collegiate Athletic Association v. Alston, 594 U.S. 69 (2021) and the rise of NIL compensation.
The Sixth Circuit’s ruling did not settle the legality of the JUCO Rule, but by dismissing the appeal as moot, the court left intact the preliminary injunction
and cleared the way for Pavia’s broader challenge to proceed. Pavia’s complaint before the district court remains pending, and he will likely continue to press his claim that he should be permitted to play another season in 2026."
Background: From the Trial Court to the Appeal Diego Pavia's journey to a NCAA Division I starting quarterback position was anything but conventional.
www.nilrevolution.com
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