Update: In 2026, the NCAA passed an age-based eligibility model that allows student-athletes at the Division 1 + 2 level to compete for five seasons in five years from the time they enroll in college or the academic year after their 19th birthday (with limited exceptions.) Student-athletes who have eligibility after the 2025-26 school year are able to take advantage of the new rule. Learn more about the NCAA 5-Year Eligibility Rule Change.
A ruling in an ongoing court case brought against the NCAA by one college football player could be the first step in major changes to what playing in junior college means for a student-athlete’s eligibility. Current NCAA eligibility rules allow student-athletes 5 years to compete athletically over the course of 4 seasons.
There are no sweeping changes yet – though days following the JUCO ruling, the NCAA granted additional eligibility to more student-athletes (more on that below) — and it’s still unknown if there will be in the future. Here’s what we know about Vanderbilt quarterback Diego Pavia’s case against the NCAA – and what happens next.
Who is Diego Pavia and why did he sue the NCAA?
Pavia transferred to Vanderbilt for the 2024 season from New Mexico State, where he was the Conference USA Offensive Player of the Year. At Vanderbilt, he led the Commodores to a 6-6 record, including an upset over Alabama.
In November, Pavia sued the NCAA arguing that the two years he spent playing in junior college before getting a Division 1 offer shouldn’t count toward his Division 1 eligibility time.
NCAA players usually have five years to complete four seasons of eligibility – Pavia and others in his class had an extra year due to the COVID-19 pandemic.
When filing the lawsuit, Pavia asked a judge to issue an injunction to allow him to compete in the 2025 season.
Right before the holiday break, a judge granted him the injunction – allowing him to compete while the case proceeds.
What is Pavia’s argument against the NCAA?
Pavia and his lawyers say that the NCAA and its member institutions violated anti-trust laws with their rules and regulations for junior college players who transfer to Division I 1 programs.
“We’re not saying the NCAA can’t have eligibility requirements,” Ryan Downton, Pavia’s attorney told ESPN.
“But a junior college season shouldn’t be the equivalent of an NCAA season when the junior college season has no meaningful opportunities to earn NIL, no television exposure. They take other athletes [who are playing somewhere outside of high school] and don’t hold those seasons against them.”
What does the judge’s ruling mean?
Judge William Campbell’s ruling grants Pavia eligibility for another season while the case moves forward – meaning he can start negotiating NIL deals and prepare to lead the Vanderbilt offense for another season.
Do all junior college transfers now have more years of NCAA eligibility?
Some do. The case will continue to make its way through the court system, and Pavia could lose the case – though the NCAA has lost several major cases in the past few years and experts said the judge seems receptive to Pavia’s argument.
In a statement to news outlets, including ESPN and Yahoo Sports, the NCAA said:
The NCAA is disappointed in today’s ruling and wants all student-athletes to maximize their name, image and likeness potential without depriving future student-athletes of opportunities. Altering the enforcement of rules overwhelmingly supported by NCAA member schools makes a shifting environment even more unsettled. The NCAA is making changes to deliver more benefits to student-athletes, but a patchwork of state laws and court opinions make clear that partnering with Congress is essential to provide stability for the future of all college.
New JUCO eligibility rules?
The week after Pavia’s injunction was granted, according to news reports, the NCAA Division I Board of Directors approved an extra year of eligibility only in 2025-26 for student-athletes who previously competed at a non-NCAA school for one or more years (which includes junior colleges) and would have exhausted their eligibility after the 2024-25 season.
The NCAA also said it would appeal the ruling in Pavia’s case.
NCSA will continue to track the on-going court case in this matter and provide up to date NCAA news here on our blog. Check back here for further developments.
For more on how JUCO fits into the bigger recruiting picture, check out our full guide: Junior College Sports Explained.