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Sixth Circuit Hears NCAA Appeal in Pavia Eligibility Case as QB Says 2025 Is His Last Season

A forthcoming decision could determine whether the NCAA’s eligibility limits are subject to antitrust law.

Overview

  • NCAA counsel Rakesh Kilaru told judges the association believes its eligibility rules comply with antitrust law and signaled it intends to keep enforcing them, forecasting more court fights.
  • Pavia’s attorney argued the rules commercially restrain athletes by counting junior-college seasons and said they could add a challenge to the redshirt limit to preserve potential 2026 eligibility.
  • Pavia publicly stated he will not play in 2026, and his attorney said the legal push aims to set precedent for future athletes rather than extend his own career.
  • Pavia’s 2025 status remains secure because the NCAA granted a targeted waiver covering certain junior-college transfers through the 2025–26 academic year.
  • The appeal comes as related cases advance across circuits, with the Third Circuit hearing the Elad case next, briefs moving in the Ninth and Fourth Circuits, and a Seventh Circuit reversal underscoring the risk of a circuit split.