NCAA’s Eligibility Model Faces Another Crack

Diego Pavia, a former college football player, has already beaten the NCAA once. Why not take another swing? This question no longer sounds outlandish after a Louisiana judge granted temporary relief to 16 former college football players, including several who have signed NFL contracts and are active participants in training camp, clearing a path for them to enter the transfer portal.

The ruling is narrow and limited to the plaintiffs, but it introduces another crack in an eligibility model that courts continue to scrutinize. Pavia would have a different argument, though a familiar one. His original lawsuit challenged the NCAA’s decision to count junior college participation against his Division I eligibility, and a federal judge granted a preliminary injunction allowing him to play at Vanderbilt in 2025.

Pavia’s Potential Path

CBS Sports spoke to a source familiar with player eligibility lawsuits who doubts Pavia would ‘fit’ in this case, citing the quarterback’s high school graduation in 2020. However, if Pavia chose to pursue his initial argument with the NCAA in 2024 that JUCO seasons ‘unjustifiably restrain’ an athlete’s potential to earn NIL dollars across four full NCAA years, he would technically be fighting for a fifth and final season.

Pavia said that in September 2025, despite ongoing efforts by his legal team for a possible seventh season in 2026, he was playing for the final time in the collegiate ranks. Pavia’s potential path could point out that he hasn’t yet received his fifth year of NCAA eligibility — as many other players have successfully challenged.

His representation previously claimed that his NCAA clock should not start while he was at a JUCO, especially in the NIL era. Pavia played two seasons of JUCO ball before four total seasons at New Mexico State and Vanderbilt. He was Heisman runner-up last season after scoring SEC defenses for 3,539 yards passing and 29 touchdowns, along with 862 yards rushing and 10 scores for the 10-win Commodores.

Five-Year Clock Argument

Unlike Pavia’s potential path to a lawsuit, former LSU edge rusher Jack Pyburn and 15 others who were granted a temporary restraining order by a Louisiana judge this week had a much clearer argument. The TRO does not constitute a final ruling in Pyburn’s lawsuit, along with others, but it provides them with immediate relief and the ability to pursue another opportunity while the case proceeds.

Pyburn’s argument centers on the NCAA’s five-year clock and his injury-shortened 2023 campaign at Florida. Pavia, by comparison, doesn’t have an injury-related card to play.

Mounting Courtroom Losses for the NCAA

Given his history, market value, and the NCAA’s mounting courtroom losses, would anyone be surprised if Pavia tested the boundary one more time? The 24-year-old quarterback has cleared waivers and seems to be running out of options unless he’s willing to be a practice-squad player or try his hand in the CFL.