The House Settlement has arrived. Colleges, universities, and athletes are all scrambling to make sense of the settlement, figure out what it means for them, and position themselves to maximize their opportunities in the next era of student-athlete compensation. This comprehensive overview explores the history of student athlete compensation, the House settlement details, the unresolved issues still in play, and predictions as to what will likely happen as this new system unfolds.
How did we get here?
The story of college athletics over the last decade has been one of constantly changing rules and regulations. This began with the birth of the NIL era. Until 2021, student-athletes across the United States competing in college athletics were unable to profit off of the use of their name, image, and likeness (NIL). In many cases, athletes had to make a difficult decision between pursuing their value and playing their sport. In one such case, former Texas A&M distance runner Ryan Trahan was forced to choose between making videos and being a college athlete after being informed that he was not permitted to depict anything related to being a college athlete in his videos, despite running being one of the unique elements of his channel.[1] Ryan eventually left the university entirely to pursue his career as a Youtuber, and he now has well over 20 million subscribers. Until recently, athletes like Ryan who had a blossoming online presence were forced to make similarly difficult decisions.
Litigation forced the NCAA to reduce the restrictions on student-athlete compensation. In O’Bannon v. Nat’l Collegiate Athletic Ass’n, 7 F. Supp. 3d 955, 963 (N.D. Cal. 2014), aff’d in part, 802 F.3d 1049 (9th Cir. 2015), a class of student-athletes that challenged NCAA restrictions on NIL compensation prevailed at trial, but it resulted in an order that instead increased the limit on education-related compensation that schools were permitted to offer student-athletes. The Ninth Circuit affirmed the increase to the limit on education-related compensation but reversed the lower court’s ruling that allowed NCAA members to provide $5,000 per year to each student-athlete in deferred cash compensation for the use of their NIL. Then the Alston case further weakened NCAA restrictions. In that case, a different class of student-athletes challenged NCAA restrictions on compensation for athletic services and education-related compensatory benefits. The class did not prevail on its challenge of NCAA rules prohibiting compensation for athletic services, and those rules remained in place.[2] However, the class did prevail in challenging NCAA restrictions on education-related compensation. In light of the Ninth Circuit’s holding in the O’Bannon case, the Alston court ultimately enjoined restrictions on non-cash education-related benefits but permitted the NCAA to continue restricting cash education-related benefits to $5,980 per year.
In June 2021, everything changed for NIL and the financial landscape of college athletics. The NCAA’s Division I Board of Directors enacted a last-minute policy change permitting all Division I athletes to profit off of their name, image, and likeness, including but not limited to profiting off of social media accounts, selling autographs, and making endorsement deals.[3] The Boards for NCAA’s Division II and Division III took similar action shortly thereafter. This sudden change to permit NIL deals was perhaps one of the most abrupt and significant changes in NCAA policy since its founding in 1906, and it initiated the current era of student-athlete compensation.
Almost immediately, the floodgates opened. Student-athletes quickly moved to take advantage of the change. The night before the change went into effect, Olivia Dunne, a former gymnast at Louisiana State University (LSU) with millions of followers across social media platforms and one of the highest NIL valuations of all student-athletes, posted on the social media platform now known as X, “NIL rules change tomorrow… let’s get to work.”[4] Like many athletes, Dunne proceeded to take full advantage of the opportunities offered by NIL to leverage their influence, with Dunne earning an estimated $9.5 million from June 2021 to September 2024.[5] Other athletes at schools around the nation similarly capitalized on the potential earnings that could be had from NIL.
But the NCAA’s last-minute attempt to head off the looming legal crisis by virtually erasing the financial regulation of NIL payments to student-athletes left several unresolved questions, and several new issues, that would eventually lead to the House case. First, it was unclear whether the NCAA’s prior prohibition of athletes earning money from their NIL value violated antitrust laws. Additionally, the sudden change in the financial regulation created new questions over how NIL deals, which are often associated with school-adjacent NIL collectives, interact with Title IX. And third, the explosion of NIL compensation into college athletics dramatically altered the financial stability of athletic departments as they suddenly had to organize donors to funnel more money through their collectives for recruiting top talent instead of the donors funding other costly initiatives that they had funded for decades: facility upgrades, coaching salaries, and subsidizing “non-revenue sports”. Some of these issues remain, but the House case was filed primarily because of the antitrust concerns. On one hand, the approval of the House settlement provides some relief to these perpetual legal issues. On the other, it may have also created new concerns that will be the focus of litigation in the new post-House era of student-athlete compensation.
The House Settlement Details
In its approved form the House Settlement authorizes and creates the following means and systems for athlete compensation:
- The College Sports Commission and the NIL Clearinghouse
- Revenue sharing with schools
- Mandatory Roster Limits and the elimination of scholarship limits
- Compensation for former athletes
NIL Clearinghouse
In accordance with the terms of this settlement that require a neutral third-party review of NIL deals (as opposed to a nontransparent NCAA investigation), the plaintiffs and defendants in the House lawsuit have agreed to create NIL Go, an online clearinghouse for NIL deals. NIL Go is run by the College Sports Commission, an independent entity from the NCAA “responsible for overseeing compliance with the new NCAA rules created in connection with the settlement around roster limits, revenue sharing and student-athlete NIL deals.”[6] In collaboration with Deloitte, the College Sports Commission created NIL Go as a system to assess whether third-party NIL deals are serving a valid business purpose and whether the compensation provided to the athlete is within a reasonable range.[7] Under the agreement, “all Division I student-athletes must report all noninstitutional NIL payments or contracts worth $600 or more to NIL Go” within five days of the NIL deal exceeding that value.[8]
The settlement also creates a new enforcement system for third-party NIL deals. The new system provides for neutral arbitration to resolve disputes arising from the NCAA members’ enforcement of third-party NIL restrictions. Judge Wilken noted that this is a marked improvement over the previous system, in which the NCAA was the sole decision-maker of NCAA rules, and the neutral arbitration “will be accompanied by due process protections and a degree of transparency that class members do not have under current NCAA rules.”[9]
The regulatory function of NIL Go will likely be a source of conflict if/when it exercises its authority to deny proposed NIL deals to the extent that they are not properly aligned with the fair market value and/or fail to advance a legitimate business purpose. For example, Deloitte reportedly shared at a gathering at the ACC spring meetings that it would have denied 70% of past deals from NIL collectives while 90% of past deals from public companies would have been approved.[10] Even though those numbers may be somewhat speculative, that alone indicates that we can expect to see a considerable shift in the manner in which collectives operate and NIL deals are made. Recent comments by schools have confirmed this notion. Lo Davis, the executive director of the University of Virginia’s “Cav Futures” collective, said in a recent interview that the collective is “out of the fundraising business” and “into the sponsorship business,” so instead of reaching out to donors to support NIL initiatives, they are “looking at opportunities to work with local, regional, and national businesses.”[11] Other NIL collectives around the nation are likely to follow a similar path and will need legal counsel to assist them in assessing the relative permissibility of different kinds of NIL deals as well as ensuring that the College Sports Commission is applying the rules evenly.
Direct Payments to Athletes
The settlement also provides injunctive relief for members of the “Injunctive Relief Class.” This section permits the NCAA and its members to modify existing rules and enact new rules governing student-athlete compensation and rosters for the ten-year period following the settlement. These modifications and new rules will apply only to those member institutions that choose to participate in the Injunctive Relief Settlement.
Under this section, the NCAA will be permitted to modify rules to allow schools to provide direct compensation to Division I student-athletes up to 22% of the average athletic revenue of Power Five schools, subject to yearly increases. The settlement refers to this total cap of compensation as the “Pool.” It is estimated that the Pool will start at just over $20 million per school in the 2025-2026 school year, thereafter, growing to $32.9 million per school in the 2034-2035 school year.
Scholarship Limits Eliminated
The Injunctive Relief Settlement also requires the NCAA to eliminate the scholarship limits challenged by the plaintiffs. This will permit schools to provide more scholarships to student-athletes than is currently allowed under existing NCAA rules, up to the maximum roster size for each team. Judge Wilken cites economics expert Dr. Rascher as estimating that the elimination of the scholarship limits could result in more than 115,000 additional scholarships being provided to Division I student-athletes on an annual basis.
But that estimate could be far from what actually occurs. Any manner of things could happen that lower that number, such as schools not fully funding scholarships for all the possible roster spots in all of their sports, conferences self-imposing limitations on roster size and/or scholarship funding, and schools cutting sports in an effort to save money and/or ensure compliance with Title IX.
Roster Limits Imposed
In accordance with the terms of the Injunctive Relief Settlement, the NCAA recently voted[12] to amend NCAA rules to adjust roster limits for Division I sports, likely as a cost saving mechanism for athletic departments. But these changes still provide some relief for student-athletes who face the prospect of losing their roster spots because of the changes. The settlement provides that settlement class members whose roster spots were taken away or would have been taken away because of the immediate implementation of the settlement are exempt from roster limits at any Division I school. The settlement further stipulates that Division I schools will use “good-faith efforts to identify . . . Division I student-athletes who were on a 2024-25 roster or were recruited to be on a 2025-26 roster and were removed or would have been removed from the roster for 2025-26 due to the implementation of the roster limits.”[13] Interestingly, not only will those identified student-athletes who were cut or had offers revoked not count toward roster limits for the duration of their remaining eligibility for collegiate competition, but they also will not be restricted from transferring back to their original school after initially transferring because of the immediate implementation of the roster limits.
These “grandfathering” provisions for student-athletes that were cut or had offers revoked by having them not count towards roster limits are a response to concerns expressed by Judge Wilken in April about what would happen to student-athletes who lost their roster spots when schools pre-emptively started preparing for the settlement. The extent to which it will assist athletes or adjust the competitive landscape, as schools may view it as an exploitable framework to effectively nullify the roster limits, is currently unclear.
Distribution of Compensation to Class Members
The defendants agreed to pay $2.576 billion in damages to compensate the almost 400,000 current members of the damage’s classes, with payments made yearly over the course of ten years.[14]
Within that damages total, the settlement creates a fund of $1.976 billion for NIL claims, to be distributed based on an allocation plan developed by economics expert Dr. Daniel Rascher, with $71.5 million going to members of the football and men’s basketball class for video game NIL injuries, $1.815 billion going to members of the football and men’s basketball class and the women’s basketball class for lost broadcast NIL opportunities, and $89.5 million being distributed for lost third-party NIL opportunities to members of the football and men’s basketball class, women’s basketball class, and additional sports class who received third-party NIL payments after July 2021 and played their sports prior to July 2021.[15]
The settlement also creates a $600 million fund labeled “Additional Compensation Claims Settlement Amount” to be distributed according to Dr. Rascher’s economic analyses.[16] A 95% share of that fund will be allocated to the “Power Five Football and Basketball Portion,” with 75/15/15% to football, basketball, and women’s basketball, respectively, distributed within the sports according to a formula that analyzes a standardized minimum amount, seniority, recruiting star rating, and performance metrics.[17] The other 5% share of the fund will be allocated to claimants from other sports who received grant in aid scholarship from the 2019-2020 school year through the end of the class period, and certain members are eligible for an expanded share “if they played certain sports at certain schools outside of the Power Five where their school’s team is among the highest revenue generating.”[18]
Unresolved Issues and Potential Litigation
Antitrust Issues
The first objections the court discussed were those relating to the Pool cap limiting compensation and benefits that each school can provide to student-athletes to 22% of the Power Five schools’ average athletic revenues each year. Some objectors to this provision argued that the cap “is anticompetitive and perpetuates the very harm that this litigation was supposed to remedy.”[19] But the court pointed to prior precedent declaring that “[s]o long as the conduct perpetuated under a settlement agreement does not per se violate antitrust law, the settlement may be approved, even if the perpetuated conduct might not withstand scrutiny under the rule of reason.”[20] Thus, the court overruled the objection because the objectors failed to point to any authority to establish that the Pool spending cap provisions are a per se violation of the Sherman Antitrust Act, and the rule of reason cannot invalidate the provisions because the anticompetitive effect of the cap alleged by these objectors has not been established with any degree of certainty.
In justifying the Pool cap, the court also pointed to the results of prior cases in which classes of student-athletes prevailed at trial in challenging restraints placed by the NCAA on student-athlete compensation. In each of those prior cases, the relief did not result in the complete elimination of those restraints. For example, the plaintiffs in the O’Bannon and Alston cases sought a complete ban on NCAA restrictions on education-related benefits, but the restrictions were merely modified to permit schools to provide up to $5,980 in cash-equivalent education-related compensation.[21] Thus, Judge Wilken reasoned that it is not necessarily unreasonable to provide relief without completely eliminating restrictions on student-athlete compensation.[22]
The question as to whether the cap on student-athlete compensation is permitted under antitrust law will likely serve as the basis for future litigation. The plaintiffs in any such litigation will not only contest the existence of the cap itself but also scrutinize the role and function of entities like the College Sports Commission, to the extent that enforcement and execution of their duties further limits athlete earning potential.
Due Process for Future Class Members
Some objectors to the settlement claim that the settlement agreement unfairly includes future student-athletes who are unknown and have unripe claims and thus will not receive notice and an opportunity to object to the settlement before it is approved and before they release their claims. The court specifically overruled these objections, noting established precedent holding that class actions settlements are permitted to cover both current and future class members.[23] Additionally, the composition of this class is “inherently transitory given that the rosters for Division I change each year.”[24]
Objections to the Settlement Based on Unfairness
Olivia Dunne, the popular former LSU gymnast, levied an objection to the settlement on the grounds that her payout from the settlement would not adequately compensate her for her losses. Before NIL was legal, Dunne had already amassed a massive following on social media with millions of followers. Appearing before Judge Wilken via Zoom, she reasoned, “[h]ad NIL rules not restricted me, my value would’ve started higher, scaled faster and grown even more,” “[i]ncluding during high school, when I was already amassing a large following but couldn’t earn money without compromising my NCAA eligibility. That lost momentum matters, and it’s been ignored.”[25]
Judge Wilken largely sidesteps these claims, noting that she supports the allocation formula developed by economic expert Dr. Rascher. The court cites precedent stating that the fact that a more favorable settlement for some members of the class (such as Dunne) could have been reached is not a sufficient reason to reject an otherwise fair and reasonable settlement.[26] Additionally, Judge Wilken reminds objectors that believe the allocations are unfair that they can opt out of the class.
Going forward, it can be expected that further legal action will result from current and former student-athletes like Dunne who believe the terms of the settlement fail to adequately compensate them for their realized injuries.
Title IX Conflicts
Title IX, the federal law that prohibits sex-based discrimination in educational programs receiving federal funding, is already a looming issue in this settlement. Both the back-damages portion of the settlement and the ongoing revenue sharing payments are likely to cause Title IX compliance issues as men will receive substantially more money than women. For example, the University of Georgia “intends to pay at least $13.5 million to football players, about $2.7 million to men’s basketball players, about $900,000 to women’s basketball players, about $900,000 to athletes from the remaining sports and about $2.5 million into new scholarships.”[27] This breakdown of revenue sharing would result in $16.2 million—almost 80% of the total $20.5 million planned—being spent on just football and men’s basketball. That figure is likely to exceed 80% of the revenue sharing being spent on male student-athletes when considering the portion of the $900,000 to remaining sports and the $2.5 million in new scholarships that will go to male student-athletes. Other schools may fund their sports in a manner that creates an even larger disparity between men’s and women’s sports, with the 75-15-5-5 formula reportedly becoming popular.[28] Under that formula, 75% of the funds go to football, 15% to men’s basketball, 5% to women’s basketball, and the remaining 5% to other programs, leading to over 90% of the revenue-share funds being allocated to men’s sports.
As of the date of this article, eight athletes have already signed onto a motion to appeal the settlement, halting payments but not revenue sharing.[29] Four more female athletes are currently appealing the lawsuit, with the lead attorney arguing that the settlement “allocates $2.4 billion to men and only $102 million to women” and thus violates Title IX.[30] The settlement will be appealed in the Ninth Circuit, and more clarity is not likely to come for several months. In the meantime, revenue sharing will go into effect, only increasing the stakes for Title IX compliance.
Conflicts with State Laws
Some objectors to the settlement argue that the settlement should not have been approved because some of its terms contradict state laws governing student-athlete compensation, and the settlement lacks the power to override the state laws that it contradicts. But Judge Wilken overruled these objections, noting that the objectors stating this claim failed to include any relevant authorities supporting their position.[31] Furthermore, Judge Wilken found that the settlement does not require the court to find that it preempts state laws regarding student-athlete compensation, and the court is not making such a finding here. The court therefore found it unnecessary to address the question of how this settlement interacts with state laws and does not resolve that issue.
Conflicts between the compensation permitted and not permitted under this settlement and the rules regarding student-athlete compensation under existing state laws will likely serve the basis for future litigation and legislative policymaking at the state level.
What’s Next?
Testing the waters of the new system
Schools are now in the process of testing out the new financial and policy frameworks created through this settlement. Over the next year, many of the questions swirling around the College Sports Commission, NIL Go, and the feasibility of its mission will be answered.
We will inevitably see how schools respond to the new financial landscape and the extent to which the new revenue sharing model will affect the competitive hierarchy within schools and among conferences. Notably, NIL collectives will likely lose their prominence. Under the pre-House NIL framework, NIL activity at any given university was largely connected to that university’s collective, affluent and passionate alumni, or fans willing to donate. But now that NIL deals have to promote a valid business purpose, and meet the standards set by the new NIL clearing house, collectives may not be able to merely pool funds from donors to distribute to athletes. To the extent that market size matters, the business activity in the region in which a school is located may generate additional NIL opportunities. In theory, this could increase the fair market value of the NIL Deals for those athletes, and shift the competitive balance for that school.
In any case, there will likely be litigation addressing NIL Go and the application of its enforcement power. In fact, on July 10, 20225, the College Sports Commission issued a memo to Division I Athletic Directors offering guidance on how they would be assessing the “valid business purpose” of NIL deals via NIL Go. The commission specified that dozens of NIL deals submitted by NIL Collectives failed to meet this new standard. This memo was met with immediate pushback, and a letter from the Plaintiff’s class counsel from House demanding the NCAA rescind the memo.
Title IX Appeals
The new system invites several questions about gender equity, especially if the allocation of funds creates a disparate impact on women’s sports. As anticipated, the objectors to the settlement have already appealed the settlement alleging Title IX violations.
On the surface, the new system seems to require schools to choose between equal distribution of revenue between men and women —potentially creating a competitive disadvantage if competitors allocate a higher proportion of the money to the men’s “revenue sports”— or a prioritized revenue allocation that could negatively impact and underfund women’s and non-revenue sports. Depending on how the pending Title IX appeals develop, the short term gain of competitive revenue allocation strategies may result in a new class of plaintiffs in another costly lawsuit, this time based on Title IX.
Predictions and Alternative solutions
In many ways the NCAA has been fighting a multi-front war. While the House settlement may appear to be a victory on the anti-trust front, this may only be a short-term solution. While this settlement will bring about broad changes to colleges sports, there are several lingering issues and concerns with colleges sports that are unaddressed by the settlement. Many of the NCAA’s critics and legal opponents have been waiting for the results of this settlement, and will likely resume their efforts for additional change.
For example, there are still several questions about the prospect of college athlete employment and collective bargaining, which will likely gain momentum under this new system of direct payments. Many critics believe that some form of collective bargaining would present a more permanent solution than leaving schools and conferences to attempt to interpret the settlement. If college sports were to adopt a collective bargaining model similar to their professional counterparts, it would allow the system to account for and address the growing needs of athletes over time.
Similarly, the NCAA has not given up on their desire for Federal legislation. The NCAA’s legislative push has primarily been focused on creating a more uniform system for athlete compensation and seeking an anti-trust exemptions, to remove the possibility of reliving their experience with the House settlement. While there have been a number of bills propose addressing NIL and College Sports, most have been sidelined by an ever-changing Congressional agenda.
Conclusion
This may be the most turbulent period in the history of college athletics. Navigating the constantly evolving landscape is challenging without talented legal counsel.
[1] Kent Smith, Former Aggie, YouTuber Ryan Trahan Shows Hog Fans Positive Side to NIL, Arkansas Razorbacks on SI (Mar. 11, 2024), https://www.si.com/college/arkansas/hogs-football/razorbacks-texas-aggies-ryan-trahan-mr-beast.
[2] See In re Nat’l Collegiate Athletic Ass’n Athletic Grant-in-Aid Cap Antitrust Litig., 958 F.3d 1239 (9th Cir. 2020); Nat’l Collegiate Athletic Ass’n v. Alston, 594 U.S. 69 (2021).
[3] Alan Blinder, College Athletes May Earn Money From Their Fame, N.C.A.A. Rules, N.Y. Times (Jun. 30, 2021), https://www.nytimes.com/2021/06/30/sports/ncaabasketball/ncaa-nil-rules.html.
[4] Olivia Dunne, NIL rules changes tomorrow… let’s get to work, X @livvydunne (Jun. 30, 2021), https://x.com/livvydunne/status/1410358923387936770.
[5] Jenna Lemoncelli, Livvy Dunne already planning next steps after becoming $9.5 million NIL legend (Sep. 13, 2024) https://nypost.com/2024/09/13/sports/livvy-dunne-planning-next-steps-next-after-becoming-9-5-million-nil-legend/.
[6] https://www.collegesportscommission.org/faq
[7] Id. (NY Post Article)
[8] NCAA Q&A page 30 Question & Answer: Implementation of the House Settlement, NCAA (Jun. 13, 2025), https://ncaaorg.s3.amazonaws.com/governance/d1/legislation/2024-25/June2025D1Gov_PhaseThreeInstSetQuestionandAnswer.pdf.
[9] SETTLEMENT 48
[10] Nick Schultz, Greg Sankey releases statement on House v. NCAA settlement approval, On3 (June 6, 2025), https://www.on3.com/nil/news/greg-sankey-releases-statement-house-v-ncaa-settlement-approval-sec/.
[11] Michael Liebermann, After two years preparing for House settlement, Virginia is ready to embrace it, The Cavalier Daily (June 24, 2025), https://www.cavalierdaily.com/article/2025/06/after-two-years-preparing-for-house-settlement-virginia-is-ready-to-embrace-it.
[12] https://www.ncaa.org/news/2025/6/23/media-center-di-board-of-directors-formally-adopts-changes-to-roster-limits.aspx
[13] Grant House v. NCAA, No. 4:20-cv-03919-CW, 13, Opinion Regarding Order Granting Motion for Final Approval of Settlement Agreement (N.D. Cal. Jun. 6, 2025) (available at https://swimswam.com/wp-content/uploads/2025/06/Grant-House-vs-NCAA-Order-Granting-Final-Approval-to-Settlement.pdf).
[14] Id. at 9. (SETTLEMENT)
[15] Id. at 9. (SETTLEMENT)
[16] Id. at 10. (SETTLEMENT)
[17] Id. at 10. (SETTLEMENT)
[18] Id. at 10 (SETTLEMENT)
[19] Settlement page 42
[20] Settlement page 42 (citing In re Blue Cross Blue Shield Antitrust Litig. MDL 2406, 85 F.4th 1070, 108990 (11th Cir. 2023) (internal citation omitted), cert. denied sub nom. Behenna v. Blue Cross Blue Shield Ass’n, 144 S. Ct. 2686 (2024), and cert. denied sub nom. Home Depot U.S.A., Inc. v. Blue Cross Blue Shield Ass’n, 144 S. Ct. 2687 (2024).
[21] See O’Bannon v. Nat’l Collegiate Athletic Ass’n, 802 F.3d 1049, 1078 (9th Cir. 2015); also see In re Nat’l Collegiate Athletic Ass’n Athletic Grant-in-Aid Cap Antitrust Litig., 375 F. Supp. 3d 1058, 1061-1110 (N.D. Cal. 2019).
[22] Settlement 3-4
[23] Page 54 settlement
[24] Page 54 settlement
[25] Caroline Price, Olivia Dunne’s Unique Objection To The House Vs. NCAA Settlement, Forbes (April 7, 2025), https://www.forbes.com/sites/carolineprice/2025/04/07/olivia-dunnes-unique-objection-to-the-house-vs-ncaa-settlement/.
[26] Settlement page 59
[27] Jesse Dougherty, House v. NCAA Settlement approved, allowing colleges to directly pay athletes, The Washington Post (Jun. 7, 2025), https://www.washingtonpost.com/sports/2025/06/06/house-ncaa-settlement/.
[28] Maura Carey, Path after NCAA settlement comes with risk, reward and warnings, The Associated Press (June 15, 2025), https://sports.mynorthwest.com/ncaa/path-after-ncaa-settlement-comes-with-risk-reward-and-warnings/1813666.
[29] Shehan Jeyarajah & Brandon Marello, House v. NCAA settlement payments on hold amid legal challenge from female athletes on Title IX grounds, CBS Sports (Jun. 11, 2025), https://www.cbssports.com/college-football/news/house-v-ncaa-settlement-payments-on-hold-amid-legal-challenge-from-female-athletes-on-title-ix-grounds/.
[30] Id. (CBS article)
[31] Settlement 64
Special thank you to Summer Associate Jackson Martingayle for his assistance with this article.
