I read the decision. For the non-lawyers, the burden was on Zeigler during the preliminary injunction hearing to prove that he is entitled to one, and it is a high burden. To prevail, Zeigler had to prove four things:

(1) that Zeigler had a strong likelihood of success on the merits of his claims (if the case went to trial);

(2) that Zeigler would suffer an irreparable injury without the injunction (money damages cannot fix the problem or the financial destruction would ruin him beyond repair);

(3) that issuing the injunction would cause harm to others (Zeigler would need to show that it wouldn't); and

(4) that public interest would be served by issuing an injunction.

The Judge found that Zeigler couldn't prove the first element, so the remaining elements were not discussed in depth. For background, Zeigler sought injunctive relief to allow him a fifth year of eligibility under two theories: the Sherman Act (federal antitrust act) and the recently enacted TTPA Act (state statute).

The Court first addressed the Sherman Act and found that Zeigler could not establish a likelihood of success on the merits under the Sherman Act. Although the Court found that the 4/5 year eligibility rule was commercial, the Court held that Zeigler could not succeed based on the rule of reason (Zeigler was required to prove that the challenged restraint has a substantial anticompetitive effect that harms consumers in the relevant market). The Court found that Zeigler's expert did not analyze the relevant market and that the NCAA is not in control of compensation (the unaffiliated collectives are in control -- i.e., Zeigler is not likely to be successful on the merits). Accordingly, the Court held that the NCAA cannot be held liable under the Sherman Act based on that lack of control. Zeigler argued that the NCAA causes secondary effects to NIL and has control over the market. The Court did not buy that argument and held "[T]here are no 'cases addressing the issue of whether a defendant is subject to antitrust liability' for an action that merely results in 'secondary' anticompetitive 'effects.' Thus, to the extent that there are secondary anticompetitive effects of the Four-Seasons Rule brought on by independent actors in the market, Plaintiff has presented no basis for holding Defendant liable."

Zeigler lost on this argument.

Next, the Court addressed the TTPA. This one is short and sweet. The TTPA (Tennessee Code Annotated § 49-7-2801, et seq.) explicitly "does not authorize, create, or afford any private cause of action, liability, or basis for injunctive or equitable relief.” Tenn. Code Ann. § 49-7-2803(b). The only entity/persons who can make a claim under the TTPA is Tennessee's attorney general. Thus, the Court held that Zeigler could not use the TTPA claim as grounds for his arguments.

Though the Court did not consider the other elements, it stated that Zeigler's damages are monetary in nature and could be obtained in a normal lawsuit (his injury isn't irreparable). Next, the Court said that the injunction would risk harming currently-enrolled players who already have a roster spot and high school seniors who might have their recruitment disrupted.