“Three Duke Football Players Challenge NCAA’s Five-Year Eligibility Rule: A Legal Battle for Fairness”
In April 2025, three former Duke University football players—Ryan Smith, Tre’Shon Devones, and Cameron Bergeron—found themselves at the heart of a major legal dispute. They filed lawsuits against the NCAA and Duke University, seeking an additional year of eligibility beyond the traditional four years within a five-year period, citing injuries, personal challenges, and economic losses due to name, image, and likeness (NIL) constraints. Here’s an in-depth look at the background, legal arguments, implications, and potential repercussions of this landmark case.
1. What prompted the lawsuit?
Under current NCAA regulations, student-athletes are typically allowed four seasons of competition within a five-year span, accommodating redshirt years. Smith, Devones, and Bergeron contended that this framework unfairly restricted their playing careers, especially considering factors such as injuries, personal difficulties, and the opportunity costs tied to NIL earnings. Their legal complaints alleged that these constraints violated North Carolina antitrust law, labeling the rule an “arbitrary” and “unreasonable restraint on competition
The players emphasized substantial economic stakes—estimating lost NIL revenue between $100,000 and $500,000 had they been permitted to continue playing at the college level .
2. Who are the plaintiffs?
- Ryan Smith: A former defensive end for Duke who competed through the 2024–2025 season, contributing 70 tackles across 56 games
- Tre’Shon Devones: Graduated from Duke and pursued a fourth year post-injury after playing earlier at Rice
- Cameron Bergeron: A four-year contributor at Duke with 100 tackles across 46 appearances, earning recognition as a team iron-man
Originally, a fourth player—a former UNC receiver, J.J. Jones—was also involved, but the focus remains on the Duke athletes
3. Legal arguments: antitrust and arbitrary enforcement
The plaintiffs used a two-pronged legal strategy:
- Antitrust Violation
They argued that the NCAA, in collusion with member institutions, effectively created a cartel. By enforcing the eligibility rule, it restrained athletes from competing longer, thereby suppressing competitive opportunities and economic freedom - Arbitrary Waiver Process
The NCAA does allow waivers for extenuating circumstances, but the plaintiffs claimed the waiver-granting process was inconsistent and capricious—evidenced when all their waiver requests were denied on April 21, 2025
They advocated for a court-issued injunction to override the rule and immediately grant them an extra season of eligibility during the NCAA’s revised landscape of transfers and NIL allowances .
4. Court proceedings: injunction denied
The hearing took place on April 22, 2025, in North Carolina Business Court, presided over by Judge Matthew Houston. Despite a three-hour session dedicated to the matter, Judge Houston denied the preliminary injunction. He determined the plaintiffs had failed to show the NCAA’s eligibility rule constituted an unreasonable restraint of trade, citing insufficient evidence to support their antitrust claim
Moreover, who already completed four full seasons of play (Smith lettered in all years, Devones had a graduate year, and Bergeron played four seasons) weakened the claim that their careers were significantly curtailed
5. NCAA and wider college athletics implications
The NCAA maintains its rationale: a five-year window ensures fairness, broad access, and competitive balance in college sports. Its position is that automatic waivers would dilute the sport’s integrity
Still, the plaintiffs argue that the current system unfairly hampers athletes’ potential earnings and development—especially when NIL opportunities exist in college but vanish under NFL uncertainty
6. Broader context: transfers and NIL
Recent changes—like expanded transfer freedoms and NIL compensation—frame this lawsuit. College sports have seen athletes move frequently and monetize their brands, reshaping NCAA policy. Simultaneously, COVID-era rulings led to extra eligibility for athletes in 2020–2021, heightening expectations for continued flexibility. Yet, the NCAA held firm against extending this flexibility indefinitely .
7. What’s next for the players?
With the injunction denied, the players’ options include:
- Appealing the decision to higher court.
- Exploring professional paths, such as the NFL or alternative leagues.
- Aligning with future policy renovation, as NCAA guidelines continue evolving.
8. Why this matters
This case intersects legal, financial, and ethical dimensions:
- Legal Precedent: A successful challenge could unravel NCAA’s antitrust protections.
- Economic Equity: Athletes would gain greater control over revenue chances tied to participation.
- Competitive Fairness: Reforms could shift power dynamics within college sports.
It also spotlights inconsistencies in waiver processes—prompting calls for clarity and transparency.
Conclusion
Though the courts have blocked their immediate victory, Smith, Devones, and Bergeron’s lawsuit spotlights critical systemic issues: athlete agency restrictions, NIL inequities, and NCAA’s gatekeeping authority. As college athletics undergo seismic shifts—from transfers to NIL—the legal terrain continues to evolve. This case may not have yielded instant relief, but it has set the stage for greater scrutiny of NCAA governance, standing at the vanguard of potential reform.
Whether their attorneys proceed to appeal or the defendants pivot toward professional careers, this suit has already resonated well beyond Duke for all collegiate athletes seeking fairness and opportunity in a rapidly changing world.
If you’d like to dive deeper into NCAA eligibility rules, ongoing lawsuits, or the future of college athletics, I’d be happy to explore further.
