The NCAA’scontracts, combinations, and relationships consist of a continuing agreement, understanding, and concert of action among the NCAA and its members, vendors, and customers, the substantial terms of which are to artificially fix, decrease, maintain, and/or restrict the amount of college athletic services in the United States.
44, Alternately, the NCAA’s_ contracts, combinations, and relationships consist of a continuing agreement, understanding, and concert of action among the NCAA and its members, vendors, and customers, the substantial terms of which are to artificially fix, depress, maintain, and/or Case 8:25-cv-00431-MSS-TGW Document1_ Filed 02/20/25 Page 11 of 22 PagelD 11 stabilize prices paid for collegiate athletic services in the United States, its territories and possessions.
The NCAA’s interference includes, but is not limited to, refusing to grant McLeana legislative relief waiver whensheis entitled to one, acting arbitrarily or capriciously with regard to McLean andhereligibility, ignoring her rights, and violating the NCAA’s own rules and guidelines.
For the reasons stated above, Plaintiff asks this Court to judge, hold, and declare that McLean has a right to compete on behalf of USF's women’s golf team in the spring 2025 season, regardless of her prior participation in a single non-championship event that did not count towards OU’s qualification for NCAA post-season play.
WHEREFORE,Plaintiff respectfully requests: (1) An emergency order enjoining the NCAA from enforcing its Competition in the Year of Transfer Rule that prevents McLean from having immediate eligibility to play golf for USF in the spring 2025 season as well as the NCAA’sRule of Restitution should the emergencyorder be later reversed;