With the injunction in place, Bustard will remain fully eligible through the end of the 2025-2026 academic year, allowing him to complete two full years at Eastern Michigan University, finish his MBA, and maximize his athletic and academic potential.
TOLEDO, OH – The national law firm Shumaker has won a pivotal court ruling that renders Eastern Michigan University football player Blake Bustard immediately eligible to compete for the entirety of the 2025-2026 season.
Michigan Judge Julia B. Owdziej granted a preliminary injunction against the NCAA, blocking enforcement of its “Five-Year Rule,” and related eligibility bylaws, that would have ended Bustard’s college football career. The case, Blake Bustard v. National Collegiate Athletic Association, No. 25-000779-CP (22nd Circuit, Washtenaw County, Michigan), had been hotly contested by the NCAA.
“This is an outstanding victory. We believe this case should set precedent not just for Blake, but for every college athlete facing arbitrary rules that can derail their careers,” said Shumaker attorney Diana Florence. “The court made it clear that the NCAA cannot hide behind outdated regulations when they cause real, life-changing harm to student-athletes. This sets a precedent for fairness and common sense in college sports.”
A Challenge to Outdated and Arbitrary NCAA Rules
Under the NCAA’s “Five-Year Rule” athletes have five calendar years to complete four seasons of eligibility. While the rule was intended to account for a redshirt year, it has often been used to deny players an additional year of eligibility — even within the five-year window and regardless of whether circumstances beyond their control prevented them from competing. For several years, the NCAA also imposed arbitrary redshirt limits on football players, like Blake, who chose to start their careers at Division II schools. While Division I football players could play in up to six games during their first season without giving up a year of eligibility, Division II players burned an entire year of eligibility after just a single play.
Shumaker argued the NCAA’s rigid application of the Five-Year Rule ignored the realities of modern college sports, including changes in transfer rules, medical hardships, and the evolving landscape of direct revenue-sharing and Name, Image, and Likeness (NIL) opportunities. Further, the disparate treatment of Division II athletes has deprived hundred, if not thousands, of student-athletes of valuable development.
“Today’s decision sends a strong message: athletes have rights, and the NCAA must adapt to this new era,” said Shumaker partner Nicholas Stack. “We’re seeing the beginning of a shift where courts will hold the NCAA accountable when its rules no longer serve the best interests of student-athletes.”
Implications Beyond This Case
The win comes at a time when the NCAA’s policies face unprecedented scrutiny, with mounting legal, legislative, and antitrust challenges reshaping the balance of power in college sports.
“This is bigger than one player or one team,” Florence added. “It’s about ensuring that every student-athlete has the opportunity to compete, grow, and pursue their goals without being unfairly cut short by bureaucracy.”
With the injunction in place, Bustard will remain fully eligible through the end of the 2025-2026 academic year, allowing him to complete two full years at Eastern Michigan University, finish his MBA, and maximize his athletic and academic potential.
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