Junior college ruling: Could Gonzaga's Michael Ajayi return in 2025?

A preliminary injunction regarding the NCAA's rules on JUCO participation has allowed one player an extra year of eligibility

Gonzaga Bulldogs senior guard Michael Ajayi. / Photo by Erik Smith, Myk Crawford

A temporary injunction allowing Vanderbilt quarterback Diego Pavia to play another season of college football in 2025 could have major implications for junior college transfers on the hardwood as well.

The NCAA has counted JUCO participation against student-athletes’ eligibility when they move up to the Division I level. For example, Gonzaga men’s basketball forward Michael Ajayi has senior status despite the 2024-25 season being just his second at the Division I level. Ajayi played two seasons at Pierce Community College before moving to Pepperdine for the 2023-24 campaign. 

Pavia, who played two seasons at New Mexico Military Institute before transferring to New Mexico State and later Vanderbilt, claimed that his NCAA clock should not have started during his time at the JUCO level, especially in the NIL era. Now that the court sided with his claim that the NCAA's rules violate antitrust law, there’s likely to be more fallout across Division I and JUCO athletics. 

The ruling isn’t a class-action and is specific to Pavia, but other student-athletes in his position could potentially follow suit. In fact, it might not even take legal action from individual players if certain schools are willing to challenge the NCAA on the matter. Evidenced by the myriad of other legal battles the governing body is facing at the moment when one lawsuit arises, another one is likely not that far behind.

The preliminary injunction grants Pavia one more season of college football while the final ruling is still to be decided, likely at some point in 2025. What does this mean for JUCO players elsewhere, particularly the seniors? Some might be forced to make a few tough decisions in the coming months.

If Pavia ultimately wins his case, there’s a chance the NCAA will be barred from enforcing its rule on other JUCO athletes. There have been two such cases recently in Tennessee and West Virginia. 

In West Virginia, a court allowed athletes who transferred a second time in their career a chance to play immediately. In Tennessee, a federal court found it was OK for boosters and collectives to negotiate with student-athletes before they enrolled in school. Both are now common practices across the college sports landscape.

In another case back in December 2023, a United States district judge ruled that the NCAA can’t limit how many times an athlete transfers. The direct impact is that players can now move freely without losing a year of eligibility. 

Then there’s perhaps the straw that could break the camel’s back one day — House v. NCAA. The $2.8-billion settlement would essentially allow schools to participate in revenue sharing with current and future players, starting at an estimated $20.5 million per academic year. That will number will also increase over time.

That all being said, an attempt to stand up for its eligibility clock might not be of the NCAA’s highest priorities. 

"The NCAA is disappointed in today's ruling and wants all student-athletes to maximize their name, image and likeness potential without depriving future student-athletes of opportunities,” the NCAA said in a statement. “Altering the enforcement of rules overwhelmingly supported by NCAA member schools makes a shifting environment even more unsettled. The NCAA is making changes to deliver more benefits to student-athletes, but a patchwork of state laws and court opinions make clear that partnering with Congress is essential to provide stability for the future of all college athletes."

If the NCAA is barred from enforcing its JUCO rules upon Pavia’s court ruling in 2025, some student-athletes could have the option to use another year of eligibility or forgo the extra year and graduate/go pro. Depending on the timeline of events, Ajayi could be one of those players.

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