NCAA argues Zeigler would be first to play 5 DI seasons in 5 years
Associated Press
Attorneys for two-time Southeastern Conference defensive player of the year Zakai Zeigler accuse the NCAA of trying to dodge facts and law by asking a federal judge to deny the Tennessee point guard's preliminary injunction seeking to play a fifth season in as many years.
Zeigler's attorneys compared the NCAA's motion filed Monday to misdirection and said it used 'cherry-picked" or 'fundamentally flawed' data ahead of Friday's hearing on the preliminary injunction request before U.S. District Judge Katherine A. Crytzer in Knoxville.
'Rather than recognize the evolution of antitrust law's application to its business model, the NCAA relies on outdated legal arguments. And rather than address the law as it is, the NCAA mischaracterizes it to defend its illegal actions,' Zeigler's attorneys wrote in a response filed Tuesday.
Zeigler sued the NCAA on May 20 over its rules limiting him to four seasons in a five-year window as an unlawful restraint of trade under both federal and Tennessee laws. His lawsuit argues he could earn between $2 million and as much as $4 million with another season.
The NCAA argued Monday that Zeigler's injunction request should be denied because he is asking the court to make him the first athlete in history to play a fifth season in Division I 'as a matter of right.' The NCAA also said using the case of Vanderbilt quarterback Diego Pavia doesn't help because that case was 'decided in error.'
Pavia, who started his career at a junior college, was granted another year to play a fifth season, a ruling the NCAA is appealing. Zeigler played four seasons at Tennessee and already has graduated. The NCAA's motion said the life of a collegiate athlete is enabled by the Four-Seasons Rule, which creates a stream of opportunities for rising high school athletes.
The NCAA argued the Four-Seasons Rule is necessary for DI athletics to exist separately from 'purely professional athletics.'
Zeigler is asking the court to eliminate lines between the NCAA's compensation rules subject to the Sherman Act and eligibility rules that don't involve compensation. The NCAA said nothing would stop Zeigler from asking for a sixth or seventh season while pursuing a doctorate degree if he wins.
"College athletics is a means to a better end for student-athletes — not the end itself,' the NCAA motion said.
Zeigler also has known since stepping on the Tennessee campus that he had five years to complete four seasons of basketball and could have challenged the Four-Seasons Rule at any time, the NCAA said.
'Whatever emergency underlies Plaintiff's request for relief is of his own making,' the motion said.
It noted Zeigler can keep playing basketball with foreign leagues or the NBA's G League since 'if he had a viable path to the NBA, given his resume, he would already be a viable prospect.'
The U.S. Department of Justice also filed a brief Tuesday encouraging the judge to apply Alston's 'flexible' rule of reason approach to Zeigler's injunction request and 'consider how the rule may benefit competition in the relevant labor market' and potentially enhance the athlete experience.
Alston was the 9-0 Supreme Court case ruling in June 2021 that opened the door for compensation. The high court agreed with a lower court's determination that NCAA limits on education-related benefits that colleges offer athletes who play Division I basketball and football violate antitrust laws.
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AP college basketball: https://apnews.com/hub/college-basketball and https://apnews.com/hub/ap-top-25-college-basketball-poll
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One other similarity between the two programs: They each had iconic home stadiums known for raucous atmospheres. Husky Stadium, with its overhanging roof on each side of the field, held the highest recorded decibel record for a college stadium for over 30 years. It was set in 1992 against Nebraska at 133.6, a record that stood until 2023 when Tennessee's Neyland Stadium registered 137 dBs against Georgia. But to the players on the field on Sept. 9, 2000, Husky Stadium — or any other football stadium — never sounded any louder. And considering the Canes quarterback, Ken Dorsey, was making his first start on the road, that made a big difference. Advertisement Tripplett: It was deafening. Dude, it was so crazy loud. I felt as if Miami was really shell-shocked as far as how loud it was and how aggressively we were playing. Joaquin Gonzalez, Miami, offensive tackle, 1997-2001: It's the loudest place I've ever played, college and pros. The two overhangs on either side of the stadium, it was just this bellowing and a resonating sound. If you look at the first part of the film, the offensive line was late off the ball. Bryant McKinnie and I were late off the ball quite a bit early on, even though we had practiced a silent count and all of that. It was hard to even get the play calling in from (QB Ken) Dorsey. The very next year, we opened up at Penn State against a record-setting crowd (109,313), and we didn't freaking bat an eye. That place was pretty freaking loud, but not as loud as that (Husky Stadium). Mike Rumph, Miami, cornerback, 1998-2001: We had never been to the West Coast before. We all were like, in awe, like, 'Holy s—, we're on West Coast.' We're like, 'All those f—ing mountains in the background.' We never seen no mountains and no hills. They got Mount Rainier, like a f—ing snow cap in the backdrop. 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But they didn't face many option teams. Back then, Syracuse was an option team, a little like us. We studied them quite a bit. The Huskies weren't running all over Miami, but Tuiasosopo was moving the ball. He led them on a nine-play, 80-yard touchdown drive that he capped off with a 12-yard run on an option keeper that featured three broken tackles. He later connected with Washington's standout tight end Jerramy Stevens for a 23-yard TD pass to give the Huskies a 21-3 halftime lead. Advertisement Myers: We did a lot of motion from the backfield to empty and threw the ball on them because we knew what they would check to. Our empty passing game was really effective in that game. We knew they would check to two-deep, so we threw option routes to Jerramy Stevens and Joe Collier and Willie Hurst, our tailback, who would be a slot receiver in our formation. It was very effective for us. I didn't recall seeing Miami play against much empty back in those days. Neuheisel: We hit a touchdown on an unbalanced scheme, and we had post-post-wheel and hit the wheel. It was good stuff. Rumph: They kept running the speed option. They found the wrinkle. They ran the speed option weak against us, and we couldn't figure it out because they kept pulling the guard with the twist. We were one man short a lot. I remember that adjustment. Tripplett: Tui was doing Tui Magic. He just makes stuff happen. And he was our leader. He was the type of leader that everybody on the team would run through a wall for. That year, we just knew as long as Tui was out there, we had a chance to win, and it proved to be true because we had some crazy comebacks that year. Alexis: The guy just had swagger about him. Just calm, cool. It doesn't matter what the moment was like. He would just be himself, calm, cool, just a born leader out there. He'd make sure everybody was not nervous. He was like that consistently all year. Those Samoan boys are different, man. Rumph: He was a real good quarterback. He could run, he could throw. He was physical. Gonzalez: We basically played like s— for a half. Santana fumbled, Dorsey fumbled. One of our other running backs fumbled as well. We had a field goal blocked. We definitely didn't start great. Miami woke up in the second half. The Canes scored their first of three third-quarter touchdowns on a 21-yard pass from Dorsey to Wayne, but the Huskies answered when Neuheisel inserted Alexis, a true freshman running back from South Florida, and called an option play with the ball at midfield. Alexis: I didn't even know if I was gonna get in the game or not, but Neuheisel told me he wanted to just throw me in the game so my parents could see that I'm doing well. He threw me in the game, and I'm looking at Dan Morgan. I'm like, dang, everybody I looked up to was against me. Advertisement I wanted to be a Hurricane all along. It came down to Miami and Washington. Neuheisel told me if I came out there, I'd play running back. He needed a big running back. Miami was already loaded at running back. You got James Jackson and Clinton Portis. Me and Willis McGahee were in the same recruiting class. Greg Schiano wanted me to play safety. The only thing I knew how to do is just run the football. Myers: We called 43-veer. That meant offensive tackle Elliot Silvers was to release inside and veer through to the first backer in the box, which would be the weakside backer, and they had taken their defensive ends and put them head up on the tackles. On the second or third series, we went to that arc option part of the scheme (reading Miami's defensive end) so that we could get their defensive end to tackle (fullback) Pat Conniff. And, if he didn't, then Conniff was to get the ball in the option, and we wouldn't end up pitching the ball. Elliot is a really, really smart kid. Their guy was really squeezing down. Elliot and (guard) Chad Ward said to me, 'Coach, we need to arc this stuff because we can't get through.' We ended up optioning the safety, the corner was being blocked and we went right down the sideline. It was awesome. Tuiasosopo: The option kept them on their heels and off-guard. It was gonna be a quick pitch. I got nailed. I was lying on the ground, but I saw him get around the corner and make that first guy miss, and I looked at their end who was on top of me and I smiled. 'That's a touchdown!' Alexis: I really didn't think he was going to pitch it. I went to the left with him, till he dove in with a quick dive, and he just pitched it to me, and I just took off. I couldn't believe I made the touchdown. I mean, I was just in shock. You watch the replay, I froze. I didn't know what to do. I was holding onto the ball. I didn't even know how to celebrate. I just ran by Mike (Rumph), the late Al Blades, I saw all these guys, and I couldn't believe I just scored. I was just so overwhelmed with joy. Washington led 27-9 with a little over six minutes remaining in the third quarter, but Miami started to heat up offensively as Portis broke some big plays and Morgan recovered a Tuiasosopo fumble to set up another UM touchdown to make it 27-22 with 3:50 left in the third. Washington, though, never wilted and kept responding. On defense, Tripplett was a menace. He had two sacks, blocked a field goal and recovered a fumble in the fourth quarter. Miami had one last chance to rally, getting the ball back with 20 seconds left at their own 20 down 34-29, but Dorsey couldn't rescue the Canes. Neuheisel: We ended up beating them because we played some slight of hand with some option and had some decent concepts to trick them in the red zone. We were able to run the ball against them some, which not very many people could. Gonzalez: I think if we have probably eight to 10 more seconds at the end of that game, we win it. There was a moment in that game where things kind of just started clicking. Advertisement Rumph: They had like 800 recruits there, and their head coach looks at us as we're leaving the field, and he goes, 'You don't want to go play there. You want to play here. You don't want to go to Miami. Play here.' I vividly remember that. And as we exited through that tunnel, their players were barking at us. We were actually trying to fight them a little bit, but they were barking. Gonzalez: It was just a s—-y situation to start the season. When you start off the season, you have all of these hopes and aspirations for all of these big things that you're going to do. You never want to start off, in any sport — no matter if you're playing Pee Wee or whatever — you never want to start off 1-1. More so in college sports at that time, one loss in any part of your season meant that you weren't a contender anymore for the national championship. You fast forward to the end of the year, and we get screwed, even after beating Florida State head to head. Because of us, really, that's why they changed the BCS. Miami finished the regular season 10-1 with wins over No. 1 Florida State and No. 2 Virginia Tech (by 20 points), but those were the Canes' only wins over ranked opponents. Washington also went 10-1, with its lone loss coming at Oregon, three weeks after beating UM. The Huskies also had just two Top 25 victories, with their other win over No. 23 Oregon State. The Noles ended up getting the title shot against No. 1 Oklahoma in the Orange Bowl, even though the Canes were ranked No. 2 in the coaches and AP polls. They were ranked third in the BCS. Delvin Brown, Miami, DB, 1997-2000: What happened that year that people don't remember is Georgia Tech and Virginia Tech had a game that was canceled because of lightning. Lee Corso's car got struck by lightning, and because Virginia Tech didn't play Georgia Tech, our strength of schedule was actually weak. If we would have had a stronger strength of schedule, even despite our loss to Washington, we would have played in the national championship game. The good news is we still got to put a spanking on Florida (in the Sugar Bowl) that year. That was the year we fought them on Bourbon Street. Alex Brown ended up being a first-round pick for Chicago. We beat him up in the bar. He was in the postgame with a black eye. Gonzalez: I remember walking out this white painted tunnel with pictures of Washington greats all around, in pain with my f—ing ribs, and just f—ing sitting there and saying, 'All this f—ing work wasted.' But I think that sparked the fire in us. To get slapped in the f—ing face the way that we did by Washington, it could have been very easy for us to go the other way. How did that become the turning point? It's hard for me to kind of verbalize. I just think that we had all worked so hard that we weren't going to let that define us. We really busted our ass that summer. UM had always had the offseason workouts. The test for stamina was always 16 110s. That's what you had to run to make sure that you were ready for the season. If you didn't, you had to run it every day until you passed it. But that offseason was the first offseason that the guys on the team said, 'No, 16, is not good enough. We gotta run 20 110s now.' Then, my senior year, we said, 'It's not 20 anymore. It's 24 110s.' Davis left the Canes after the season to become the Cleveland Browns coach. Offensive coordinator Larry Coker was promoted after Miami's veteran leaders, who had opted to stay in Coral Gables, lobbied the school's AD, Paul Dee, to make that move for continuity's sake. The Canes opened the 2001 season at Penn State and destroyed the Nittany Lions, 33-7. They pounded Rutgers 61-0 with the rematch against Washington, who had beaten No. 11 Michigan, up next. But then 9/11 happened. Like most games that weekend, it was postponed. The game was tentatively rescheduled for Thanksgiving weekend, when both schools had open dates. Advertisement Neuheisel: We had just beaten Washington State. We were beat up. We were 8-2. I told (Washington AD) Barbara (Hedges), 'Barbara, just tell them that we'll do it another year. We don't need to go.' She said, 'Oh, we have to.' I said, 'No, we don't. Other people have turned it down. We'll play 'em another year.' We went and got waxed. Myers: I can remember sitting in the staff room and Rick was adamant about not playing that game because we didn't need to. A lot of people around the country weren't replaying that game they'd missed early in the season because of 9/11. Rick was not happy about it. In addition to beating Michigan, Washington had defeated No. 10 Stanford and No. 9 Washington State. Miami had blown out No. 13 Florida State on the road and beat No. 15 Syracuse 59-0. The Canes — and their fans — were primed for the Huskies. Myers: As soon as we got down there to the Orange Bowl parking lot, they were throwing oranges at our bus. The fans were ready for us. That was crazy. Tripplett: They were throwing oranges at us. Little kids were giving us the finger. They were really pissed at us. On the second play of the game, Miami linebacker Jonathan Vilma intercepted Washington QB Cody Pickett. Miami needed one play, a Portis run, to score its first touchdown. In the next series, UW went on a 15-play drive. Alexis broke a 31-yard run up the middle to the 2, but the Canes stiffened and stuffed four successive runs. Myers: From then on, we didn't move the ball hardly at all. It was like we poked the bear. They just bludgeoned us after that. We couldn't move the big man from the Patriots, (Vince) Wilfork, at all. Gonzalez: We beat them up and down every f—ing which way, and every facet, every metric that you could imagine in the f—ing game. And I remember that the athletic director for Washington said that they would never play us again. I do remember Larry Coker calling a timeout only to allow the seniors to come out of the game because we're already winning by a lot. And I do have a beautiful picture of me and (offensive lineman Martin) Bibla in the center of the Orange Bowl with our helmets up, walking off the field in the middle of the fourth quarter, whatever it was. Advertisement But I do remember at some point in that game, I don't know when that was in the second or the third quarter, I remember standing up on top of the bench and calling the whole team together and (saying), 'Don't you ever f—ing forget what these guys did to us last year. You f—ing shove it down their f—ing throat and you f—ing make them feel the f—ing pain that we felt last year.' Those were the exact words that I used. I remember that. My hands are shaking. I'm ready to f—ing run through a f—ing wall right now. I remember telling the guys that.' Miami led Washington 37-0 at halftime and won 65-7. Pickett fumbled twice and was sacked four times. The Canes intercepted six passes. Miami went on to win the national title, with the 2001 team regarded as one of the greatest in college football history. Tripplett: I don't know if they felt this way or not, that cross-country flight is a beast. That was a challenge. I'm not using that as an excuse, but it definitely plays a role, and I wonder if it played a role at their end as well. They had a different mindset. They were trying to beat us down, and that's exactly what they did. We were not ready. We had Cody Pickett, he was young. Reggie Williams was a freshman. This was not the Tui-led Huskies in that game. Rumph: Damien Lewis, Dan Morgan, feel bad for those guys. I mean, the 2000 team was probably just as good or better than the 2001 team. But we lost that game. Tripplett: I remember when I got into the league, I played with Reggie Wayne (with the Colts), and I'd joke that they were basically an all-star team. They had so many first-rounders (15) and the only first-rounder we had was our tight end, Jerramy Stevens. Many of the players in the 2000 and 2001 Miami-Washington games now have sons who are college recruits themselves. Miami head coach Mario Cristobal was a grad assistant on the UM staff in 2000 when the Canes lost but wasn't on staff when Miami got its revenge in 2001 because he'd taken the O-line job at Rutgers when Schiano became the Scarlet Knights head coach. One of Cristobal's big recruits in the 2026 class is a South Florida kid whose family knows all about the Washington-Miami rivalry — running back Javian Mallory, the nephew of Rich Alexis. Alexis: It was a full circle moment because we had a lot of people amongst our family who are Canes at heart. Now, you got one that's actually going to be a Cane. We got one, at least. (Top photos of Rick Neuheisel, Reggie Wayne: Otto Greule Jr. / Allsport)
