In this week’s Film Room, we catch you up on recent activity in eligibility cases as well as the dismissal of Chalmers v. NCAA and scheduling in Schroeder as we wait for party submissions and a decision in House.
House
The parties in House are expected to submit revisions to the proposed settlement regarding the application of roster limits.
As the parties warned at the April 7 hearing and in subsequent briefing, changing roster limits now will cause a logistically disruptive ripple throughout the membership. We’ll know more about the challenges and approach to unwinding (rewinding?) roster limits following the parties’ forthcoming submission to the Court.
Eligibility Cases
Cases challenging the NCAA’s eligibility rules continue to result in disparate outcomes in courts across the country.
An April 25, 2025, opinion by a federal district court in New Jersey granted the request of Jett Elad, a Rutgers University football student-athlete, enjoining the application of eligibility rules that would have precluded him from competing this coming season. Like Pavia and other eligibility cases, Elad challenges the inclusion of JUCO years in the NCAA eligibility analysis.
Alberto Osuna, a baseball student-athlete whose similar request was denied by a federal district court in Tennessee last month, requested that the court revisit its decision, given the result in Elad.
Chalmers v. NCAA
On April 28, 2025, a federal court in New York dismissed with prejudice (case over, pending appeal) Mario Chalmers’ NIL-related claims against the NCAA, holding that the claims were time-barred (too late and without a legal justification for the delay) and precluded by results in other cases (O’Bannon and Alston) that addressed the same subject matter.
Schroeder v. University of Oregon
Having denied the majority of the defendant’s motions for judgment and dismissal, the court in Schroeder (Title IX) entered the parties’ joint request to move certain deadlines further into the future. For example, the order provides that discovery should end in early 2026 and any dispositive motions be filed in July 2026. As such, it seems like it will be some time before we learn the Court’s position on plaintiffs’ Title IX NIL argument and claims.
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