Frank N. Darras
Founding Partner
DarrasLaw
Email: frank@darraslaw.com
Western State Univ COL; Fullerton CA
The influence of name, image, and likeness (NIL) rights continues to push the boundaries of college sports in unprecedented ways. From the ripple effects of the transfer portal to the ongoing antitrust battles in federal court, nearly every aspect of college athletics is now touched by the high stakes of athlete endorsements - including pending litigation and a patchwork of NIL laws and guidelines.
As we approach the midpoint of 2025, let's review the power plays and upsets for NIL stakeholders and consider how sports lawyers can guide our athletes through new and evolving regulatory hurdles.
The transfer portal and shifting power dynamics
New Division I transfer rule changes were implemented to make transferring "more flexible and streamlined," according to the National Collegiate Athletic Association (NCAA). Key updates included earlier portal access, one-time transfer exceptions, and stricter academic standards (requiring a minimum 2.0 GPA) to maintain academic integrity. These changes also eliminated restrictions on the number of transfers an academically eligible athlete can make during their career, provided they remain in good academic standing.
With that in mind, remember the name Nico Iamaleava, as a precedent or rule could soon bear his name. His departure from Tennessee to UCLA marks a pivotal moment in the transfer portal era. Despite leading the Volunteers to a College Football Playoff appearance in 2024, Iamaleava announced his move to UCLA via Instagram on April 20, following a failed attempt to renegotiate his NIL deal from $2.4 million to $4 million. Iamaleava's decision to leave due to compensation disputes underscores the shifting power dynamics between athletes and programs. Notably, his move to UCLA-reportedly for a lesser NIL deal-coincides with his younger brother, Nico, also transferring to UCLA. These events signal a trend where top players may prioritize personal factors over financial gain, potentially reshaping future transfer decisions and NIL strategies.
In 2025, with his transfer to UCLA, Nico Iamaleava will still be considered a redshirt sophomore, as he has three years of eligibility remaining under the NCAA's five-year clock rule.
The growing influence of NIL negotiations on player movement has further repercussions. At UCLA, Nico Iamaleava is expected to take on the starting quarterback role for the 2025 season, signaling the departure of Bruins quarterback Dermaricus Davis, a four-star recruit ranked as the third-best QB prospect from California in the 2024 recruiting class. This high-profile move highlights the volatility of the college landscape, as coaches seeking to build a legacy may now face new risks and rewards when connecting with marquee players they did not recruit.
Eligibility rules, legal challenges and antitrust implications
NIL deals and antitrust laws are also influencing player eligibility. In an April court decision involving Jett Elad, a 24-year-old Division I transfer to Rutgers University, a U.S. district judge granted a preliminary injunction allowing Elad to continue playing for the Scarlet Knights in the fall, despite having exhausted his NCAA eligibility.
U.S. District Judge Zahid N. Quraishi concluded that NCAA eligibility rules - which limit athletes to four seasons of intercollegiate competition, including junior college seasons - are problematic under antitrust law. Division I football players are part of a labor market and can secure lucrative endorsement deals, using college football as a platform for the NFL.
"[The] injunction is potentially Elad's only opportunity to complete his Division I career and transition into the NFL," wrote Judge Quraishi.
The court's injunction prevents the NCAA from declaring Elad ineligible for the upcoming season, enhancing his chances in the 2026 NFL draft. This legal decision may also spark further discussion about the evolving nature of college sports and their increasing resemblance to professional leagues or minor league systems.
The House settlement: Roster limits and revenue sharing
The interconnectedness of eligibility, the transfer portal, and the billions of NIL dollars at stake all hinge on the pending settlement in House v. NCAA.
House v. NCAA is a federal class action antitrust lawsuit filed in the Northern District of California by college athletes against the NCAA and major conferences (ACC, Big Ten, Big 12, Pac-12, and SEC). The plaintiffs allege that NCAA rules unlawfully restricted athletes from earning NIL compensation, thus violating antitrust laws. The settlement also encompasses related cases, including Hubbard v. NCAA and Carter v. NCAA.
Senior District Judge Claudia Wilken has been presiding over the settlement for months, meticulously reviewing every detail to ensure the new rulebook is properly finalized. On April 23, 2025, she introduced a significant obstacle that could jeopardize the agreement. Judge Wilken demanded that the parties revisit the section of the proposed $2.8 billion settlement pertaining to roster limits - a provision several schools have already begun to implement.
The NCAA currently limits the number of scholarships a team can offer but does not restrict total roster size. For example, FBS football programs are allowed 85 scholarships but typically carry up to 120 players, including walk-ons. Under the settlement, new roster limits would cap the total number of athletes per team, though exact figures have yet to be finalized.
This change is designed to control financial exposure for schools, which under the settlement would share up to 22% of their athletic revenue directly with athletes. Fewer roster spots would mean fewer athletes splitting those funds. However, the proposal has drawn criticism for potentially reducing opportunities for non-scholarship athletes, especially walk-ons, and raising Title IX concerns if women's sports face disproportionate cuts or unequal revenue-sharing benefits.
Judge Wilken warned that unless these issues are addressed, the court may withhold final approval of the $2.8 billion settlement, giving all sides 14 days to contact their mediator and return to the bargaining table.
More hurdles to clear
These are just some of the many issues challenging the NCAA and the state of college athletics. Until Congress establishes a federal framework, this patchwork of rules will continue to govern athletic activity both on and off the field.
Stakeholders need support with strategy and decision-making, and sports lawyers can provide our athletes and schools with the guidance necessary to ensure compliance. This will help maintain the integrity of college sports and suggest innovative ways to move forward in this new, NIL-driven era of athletic competition.