One Quarterback, One Lawsuit, One NCAA Earthquake
Vanderbilt quarterback Diego Pavia has thrust the NCAA’s eligibility rules into the national spotlight, arguing that counting junior college play toward the five-year eligibility window violates antitrust laws under the Sherman Act. Backed by a preliminary injunction, Pavia is playing through the 2025 season, even as the courts weigh whether the NCAA’s “five years to play four seasons” rule unfairly penalizes JUCO athletes. For Pavia, who began at New Mexico Military Institute in 2020, then played two seasons at New Mexico State before transferring to Vanderbilt, the outcome of this case isn’t just about his future; it’s about the rights of future players who follow a non-traditional path. With more than 20 comparable lawsuits already filed challenging the NCAA eligibility for JUCO athletes or those affected by the redshirt/five-year rules, many may see Diego’s case as a precursor.
The Numbers Behind the Challenge
Pavia’s career trajectory is central to the legal arguments. After two JUCO seasons, one of which was impacted by the NCAA’s COVID waiver, he played at New Mexico State in 2022-23, then transferred to Vanderbilt for 2024. In the 2025 season, Vanderbilt is off to a strong start, currently 3-0, with Pavia completing about 73.5% of his passes for 645 yards and seven touchdowns in just three games. While rushing for another 129 yards on 30 carries, showing that he's still performing at a high level. The court’s temporary injunction allows Diego to play this season despite NCAA rules that would have otherwise ended his eligibility. The NCAA issued a blanket waiver for the 2025-26 year covering JUCO players who would’ve exhausted eligibility, highlighting how prevalent this issue has become.
From Redshirts to NIL: The Ripple Effect
If the appeals court finds that the eligibility rules violate the antitrust law, the effects could be seismic. Programs may need to adjust their redshirt policies, or the NCAA could be forced to change how they count, or do not count, redshirts. JUCO seasons, and athletes might see expanded opportunities to compete and earn NIL even if they begin in non-NCAA institutions. Likewise, recruiting could shift; schools might invest more in identifying JUCO talent, knowing that eligibility won’t be blocked by counting early play. There’s also the financial side: players argue that when earlier seasons count toward eligibility, it shortens their window for earning NIL and showcasing skills to professional scouts. Historically, this isn’t the first time NCAA eligibility has been challenged; nonetheless, this case may be one of the largest in scope. The pattern could reshape the balance of power between the NCAA as a governing body and athletes as laborers under the law.
One Verdict, Infinite Repercussions
Pavia has stated this will be his final college season, but his attorneys are pushing for clarity that protects future players. The court’s ruling is expected to address whether the NCAA rule is lawful under any antitrust statutes and could lead to broader changes in eligibility for JUCO transfers and redshirt rules. For college football, this case could be the tipping point toward more athlete-friendly regulations or systemwide reforms. A favorable decision for Diego could spark similar lawsuits from athletes in other sports, forcing the NCAA to overhaul eligibility policies across the board. This also raises the possibility of conference-level reforms, where leagues might adopt their own eligibility standards if the NCAA loses control of the framework.
