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Zakai Zeigler appealing denial of motion for preliminary injunction in eligibility lawsuit

ns_headshot_2024-clearby: Nick Schultz06/17/25NickSchultz_7
Tennessee PG Zakai Zeigler
(Matt Pendleton | Imagn Images)

Zakai Zeigler is appealing the denial of a motion for a preliminary injunction in his eligibility lawsuit. The denial officially came last week.

Zeigler is seeking a fifth year at Tennessee despite playing the last four years for the Volunteers. In the suit, he takes aim at the NCAA’s five-year rule, which states athletes have five years to play four seasons in their respective sport. Zeigler’s argument is the rule is “an unlawful restraint of trade under federal and state antirust laws.”

Judge Katherine A. Crytzer of the U.S. District Court for the Eastern District of Tennessee at Knoxville denied a motion for a preliminary injunction. Zeigler is officially appealing that decision, his lawyer Alex Little wrote in Tuesday’s notice.

In the suit, Zeigler’s attorneys argued he would miss out on millions of dollars in NIL earnings if he can’t play next season. Data from the Tennessee-focused NIL collective, Spyre Sports Group, shows his value ranges from $2 million to $4 million.

“Based on projections from Spyre Sports Group, the NIL collective associated with the University of Tennessee, Zeigler’s NIL valuation for the 2025-26 season ranges from $2 million and $4 million,” the initial complaint states. “This valuation reflects the market value of an upperclassman with a proven performance record and high visibility, especially in a high-profile conference like the SEC.”

In her denial of a preliminary injunction, Crytzler noted the timing of Zeigler’s suit, but also pondered whether the five-year rule has “anticompetitive effects in the market for student-athlete services and NIL compensation in Division I basketball,” she wrote in her opinion. She also pointed to the lack of impact the market had on Zeigler’s case.

“Without more, Plaintiff has not shown that Defendant’s limit on the labor side of the market—replacing one Division I basketball player with another – produces substantial anticompetitive effects … (demonstrating that limiting labor – who can play – may increase wages – NIL compensation – and that increasing labor may actually decrease wages),” Crytzler wrote. “And Plaintiff provided no other basis for the Court to conduct the required “fact-specific assessment of market power and market structure to assess” the Four-Seasons Rule’s “actual effect on competition” marketwide.”

Zakai Zeigler appeared in 138 games over his four years at Tennessee and started every game in 2024-25, leading the Volunteers to the Elite Eight of the NCAA Tournament. He set new career-highs with 13.6 points, 2.9 points and 7.4 assists per game.