Antitrust Law Daily Wrap Up, ANTITRUST—M.D.N.C.: NCAA tennis prize-money class action settlement approved, (Jul 7, 2026)

By Martin A. Steinberg, J.D.

Court allows notice to proceed for settlement providing a $2 million damages fund and expanded prize-money rights for pre-enrollment Division I tennis athletes.

The federal district court in Greensboro, North Carolina preliminarily approved a proposed class settlement in an antitrust action challenging NCAA rules that restricted Division I college tennis eligibility based on athletes’ acceptance of outside prize money. The settlement provides injunctive relief allowing pre-enrollment tennis athletes to keep all prize money earned in tournaments without losing Division I eligibility, but it does not require the NCAA to change rules sharply limiting prize money retained by current college athletes. The NCAA also agreed to create a $2 million damages fund for eligible athletes who submit valid claims for forfeited prize money through November 21, 2025 (Brantmeier v. National Collegiate Athletic Association, No. 1:24-cv-00238-CCE-JEP (M.D.N.C. Jun. 29, 2026)).

Background. The NCAA’s Division I tennis rules allowed athletes to play in outside tournaments but sharply limited how much prize money they could keep without jeopardizing eligibility. Prospective athletes could keep up to $10,000 annually plus expenses before enrollment, while current athletes could keep only expense reimbursements.

Reese Brantmeier and Maya Joint, both elite tennis players, alleged that these rules forced them to forfeit substantial prize money to maintain Division I eligibility, and they sued under Section 1 of the Sherman Act, alleging unlawful price-fixing and group-boycott conduct. They sought certification of both an injunctive class covering athletes who competed in or were rendered ineligible from Division I tennis because of the prize-money rules, and a damages class covering athletes who forfeited prize money. The court certified two classes: a Rule 23(b)(2) injunctive class and a Rule 23(b)(3) damages class, after finding the applicable Rule 23 requirements satisfied. The plaintiffs then moved for preliminary approval of the proposed class settlement under Rule 23.

Proposed settlement. The proposed settlement provides two principal forms of relief, but they differ significantly between prospective and current Division I tennis athletes. The injunctive relief mainly benefits athletes before they enroll in college. Under the settlement, pre-enrollment tennis players may keep all prize money earned in tennis tournaments without losing eligibility to compete in NCAA Division I tennis. The settlement does not, however, require the NCAA to change its existing rules for current college tennis players, whose ability to retain prize money remains severely restricted.

For the damages class, the NCAA agreed to establish a $2 million settlement fund. That fund will be distributed among athletes who submit valid claims showing that they forfeited prize money during the damages class period, which ended on November 21, 2025. Payments will be made according to the proposed allocation plan.

The settlement also includes releases of claims. Members of the Rule 23(b)(2) injunctive class must release future claims for injunctive relief challenging the NCAA prize-money rules that existed or continue to exist. Because members of an injunctive class generally cannot opt out, they would be barred from bringing another lawsuit seeking an injunction against those prize-money rules.

The damages-class release is narrower. Damages class members who do not opt out must release damages claims that accrued during the class period ending November 21, 2025. But they are not barred from bringing future damages claims if, after that date, they earn prize money, are required to forfeit it, and seek damages based on that later forfeiture.

Because the settlement classes were the same classes the court had already certified, the court largely relied on its prior certification findings. Subject to further review at final approval, the court adopted its earlier conclusions that the Rule 23 requirements were satisfied, including numerosity, commonality, typicality, adequacy, and, for the damages class, predominance and superiority. The court also relied on its recent order adding another class representative in addressing the adequacy of representation.

Settlement fairness and class concerns. For the damages class, the court found the proposed claims process reasonable and fair. It also found the allocation plan sensible because it provided for pro rata distribution of the settlement fund among approved and validated claimants.

The court did, however, identify potential adequacy concerns. Those concerns stemmed from the fact that the settlement provides no injunctive relief for current Division I tennis players and requires members of the injunctive class to release future injunctive claims challenging NCAA prize-money rules. After considering counsel’s explanations, supplemental materials, the overall settlement, and the hearing discussion, the court was willing to proceed with preliminary approval, while leaving those concerns open for further consideration at final approval if objections are filed or circumstances warrant.

The court next addressed notice, timing, and logistics. It found the proposed notice plan adequate because it would inform class members through several channels, including the class website, news media, social media, email, and mail. The court concluded that this plan was reasonably calculated to inform class members of the settlement and their rights. The long-form and short-form notices, as amended, sufficiently explained the settlement’s substantive terms and class members’ rights.

Objections, opt-outs, and claims. The court approved 90 days for class members to object and for damages-class members to opt out. The objection and opt-out deadline was set for September 28, 2026. The court also addressed the claims deadline. Although the original proposed notice did not include a claims deadline, the plaintiffs had proposed that claims be filed within 90 days of the preliminary approval order. The court instead set the claims deadline at 30 days after final approval, reasoning that some class members might reasonably prefer to wait until the settlement becomes final before submitting a claim. The court clarified that submitting a claim form before final approval does not waive or release claims unless and until final approval is granted.

Finally, the court simplified the objection and opt-out procedures. Objections need only be filed with the Clerk of Court, and opt-outs need only be sent to the settlement administrator. The court rejected any unnecessary requirement that objections or opt-outs also be sent to counsel, because the parties can review objections and opt-outs through the docket. The court also found that RG/2 Claims Administration LLC, already serving as notice administrator, was qualified to serve as settlement and claims administrator.

Conclusion. The court found that the proposed settlement likely satisfies Rule 23, granted preliminary approval, appointed RG/2 Claims Administration LLC as settlement and claims administrator, and approved the amended notice plan.

The administrator must distribute notice within 30 days by email, postcard, digital/social advertising, press release, class website updates, and a telephone assistance line. The claims period begins July 13, 2026. Damages class members must opt out by September 28, 2026, and any objections also must be submitted by that date. Claims for payment are due 30 days after final approval, if granted.

The court preliminarily approved the damages allocation plan and set the final-approval schedule: the final approval motion is due November 30, 2026; any fee, cost, and service-award motion is due December 11, 2026; and the final fairness hearing is scheduled for January 8, 2027, in Greensboro, North Carolina.

The Case is No. 1:24-cv-00238-CCE-JEP.

Judge: Eagles, C.

Attorneys: Daniel Kent Bryson (Bryson Harris Suciu & Demay, PLLC) for Reese Brantmeier. Calanthe Arat (Wilkinson Stekloff LLP) for National Collegiate Athletic Association.

Companies: National Collegiate Athletic Association

Cases: Antitrust NorthCarolinaNews