Sidley Helps Secure Appellate Victory for Princeton University in Ivy League Athletic Scholarships Antitrust Class Action

Sidley recently helped obtain a significant appellate victory for Princeton University in the United States Court of Appeals for the Second Circuit. On April 2, 2026, a three-judge panel unanimously affirmed dismissal of antitrust claims challenging Ivy League rules prohibiting athletic scholarships.

The putative class action, originally filed in the U.S. District Court for the District of Connecticut, was brought by two former Brown University basketball players. The plaintiffs alleged that the Ivy League Athletic Conference and its member schools unlawfully conspired to prohibit athletic scholarships. The plaintiffs claimed that the Ivy League’s rule prohibiting athletic scholarships constituted a price-fixing scheme that suppressed compensation and raised the price of education for student-athletes in violation of Section 1 of the Sherman Act.

Following oral argument, the Second Circuit held that the plaintiffs’ claims were correctly dismissed as a matter of law because the complaint failed to properly plead a relevant market in which competition was supposedly impaired. In doing so, the Second Circuit rejected the plaintiffs’ attempt to plead an “Ivy League-only” market, noting that the complaint itself acknowledged that Ivy League schools compete for student-athletes with non-Ivy League schools that offer athletic scholarships.

Notably, the Second Circuit also stressed that, while courts have held that the NCAA may not limit education-related compensation and benefits, individual conferences do not have the same level of market dominance, and as a result, can implement their own rules that are stricter than those required by the NCAA without violating the antitrust laws.

This decision represents a significant legal victory that recognizes the ability of college athletic conferences to unilaterally adopt rules that are stricter than those implemented by the NCAA. The decision also protects Ivy League schools’ longstanding commitment to solely offer need-based financial aid and to treat student-athletes and non-student-athletes equally when it comes to financial aid awards.

The ruling provides helpful guidance on antitrust market definition in the college athletics context and underscores that individual conference rules remain permissible under the antitrust laws, even where the NCAA’s ability to adopt similar rules may be restricted.

The Sidley team was led by Juan A. Arteaga and Rosa M. Morales (Antitrust and Competition). Before joining Sidley, they represented Princeton University in securing the dismissal of this action in the U.S. District Court for the District of Connecticut.