Last year, Vanderbilt quarterback Diego Pavia was given an extra year of eligibility after a federal judge in Tennessee granted him an injunction that went against the long standing NCAA eligibility rules for junior college transfers[1]. This year, Pavia wants to change the eligibility rules once and for all. Pavia and his lawyers are preparing to file an amended complaint that will add multiple players to his original lawsuit, making it a proposed class action[2].
Pavia started his first 2 college football seasons at a junior college before transferring to a Division 1 program at New Mexico State in 2022, starting the clock for his NCAA eligibility. Pavia then transferred to Vanderbilt in 2024, where he was the quarterback for the 2024-2025 season[3]. According to the current NCAA rules, Pavia’s eligibility should have ended there. Currently, the NCAA allows for athletes to play four seasons in five years, but any time spent playing at junior colleges, which are not NCAA institutions, counts against those four seasons[4].
Going against this longstanding NCAA rule, Pavia filed a complaint against the NCAA last December, arguing that his years of playing at a junior college should not count towards his NCAA Division 1 eligibility[5]. Pavia also claimed that the NCAA’s current eligibility rules violated antitrust law because they prohibited him from maximizing on his name, image, and likeness earnings[6]. The court agreed, granting Pavia the injunction that allowed him to play this 2025-2026 season. This injunction only applied to Pavia and did not take down the NCAA eligibility rules all together[7]. In response to the injunction, the NCAA did grant a waiver for the 2025-2026 season that allowed any athlete who started their career in 2020 or 2021 and played at least one season at a junior college an extra year of eligibility, although it does not apply to any future athletes[8].
Although Pavia stated he intends to declare for the 2026 NFL draft, he hopes to set completely new precedent nationwide and potentially permanently change how the NCAA qualifies junior college seasons for future athletes with the new amended complaint[9]. Pavia’s suit will likely be consolidated with up to five other NCAA football athletes who have filed similar complaints, potentially classifying Pavia’s complaint as a class action suit that aims to allow any junior college transfer to obtain the same results as Pavia in the future[10].
[1] Amanda Christovich, Diego Pavia Can Player Next Year After Ruling That Could Shake NCAA, Front Office Sports (December 19, 2024).
[2] Amanda Christovich, Deigo Pavia Is Trying to Kill NCAA JUCO Eligibility Rules for Good, Front Office Sports (October 24, 2025).
[3] Id.
[4] Christovich, supra note 1.
[5] Id.
[6] Id.
[7] Id.
[8] Alex Daugherty, Vanderbilt QB Deigo Pavia’s lawsuit aims to change junior college eligibility rules, Yahoo Sports (October 24, 2025).
[9] Alex Byington, Vanderbilt QB Diego Pavia aiming to end NCAA’s JUCO eligibility rule with class action lawsuit, On3 (October 24, 2025).
[10] Daugherty, supra note 8.
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