Ole Miss shouldn’t have starting quarterback Trinidad Chambliss on its roster this fall, the NCAA asserts in an appeal filed with the Supreme Court of Mississippi on Thursday. 

In a petition authored by J. Douglas Minor, Jr. and other attorneys from Holland & Knight, the NCAA warns that unless the state Supreme Court intervenes, there could be a “flood of litigation” involving college athletes whose schools are denied medical waivers to let them keep playing. The NCAA also says the appeal needs to be adjudicated prior to April 23 so that Chambliss—if the NCAA can enforce its eligibility rules to render him ineligible—would “have the opportunity to participate in the upcoming NFL draft.”

The appeal faces hurdles. For starters, it is an interlocutory appeal, meaning an appeal before a final judgment in a case and one where the appellate court can decline. Interlocutory appeals are disfavored because appellate courts prefer to review cases only after a final judgment on the merits—i.e., after a trial verdict—because the record is complete by that point. An interlocutory appeal concerns only a preliminary or incomplete matter. Interlocutory appeals are ordinarily denied unless the petitioner can persuasively explain that an injustice would otherwise occur.

Last month Judge Robert Whitwell of the Lafayette County (Miss.) Chancery Court granted Chambliss—who will enter his sixth year of college this fall—a preliminary injunction to bar the NCAA from rendering Chambliss ineligible in the coming season. The NCAA limits eligibility to four seasons of intercollegiate competition, including junior college and Division II competition, within a five-year period. Chambliss exhausted his NCAA eligibility in 2025–26.

The center of the dispute concerns the 2022 season, when Chambliss, now 23, was on the roster of D-II Ferris State but didn’t accumulate passing or rushing statistics. 

During that season, Chambliss suffered from post-COVID complications including chronic tonsillitis and adenoiditis. The NCAA maintains that a waiver application filed by Ole Miss on Chambliss’ behalf failed to include sufficient medical documentation establishing that Chambliss couldn’t play in 2022. The association insists it consistently applies a standard for waivers that requires contemporaneous medical records from health care professionals unambiguously establishing an athlete can’t play due to health reasons.

The NCAA says Ole Miss came up short on that front. 

As the NCAA tells it, although the Ole Miss application “was voluminous,” it offered only limited contemporaneous medical documents. The NCAA says that the treatment notes of one doctor recommended that Chambliss not have surgery and that medication, including Flonase, “was prescribed to enable [Chambliss] to participate in football.” That narrative suggests that Chambliss was healthy enough to play.

To be clear, Chambliss’ legal team contests this account and argues the medical documentation was sufficient to show he was unable to play in 2022. The appeal, as the NCAA acknowledges, also doesn’t call for a review of the findings of fact, which Whitwell found persuasive enough to grant the injunction.

In its petition to the state Supreme Court, the NCAA argues that Chambliss—who is represented by attorneys Tom Mars, William Liston III and W. Lawrence Deas—tried to “circumvent” case precedent in Mississippi. That precedent, the NCAA maintains, holds that judicial review of athletic association decisions is highly deferential to the association. Chambliss allegedly “circumvented” this precedent by insisting he is a third-party beneficiary of the contractual relationship between the NCAA and Ole Miss as a member institution.

A third-party beneficiary enjoys enforceable legal interest in the contract being performed, and Chambliss asserts the NCAA harmed him by how it reviewed the “total circumstances” of Ole Miss’ application. He used that theory to claim the NCAA breached the implied covenant of good faith and fair dealing, which collectively require parties to treat other contracting parties’ situations in a fair and honest way.

The NCAA maintains that the applicable standard of review under Mississippi law for review of an athletic association’s eligibility decision is arbitrary and capricious. This standard, which was established in the state Supreme Court case Mississippi High School Activities Association v. Hattiesburg High School (2015), is extremely favorable to the association. Per this precedent, an athletic association’s eligibility decision can be upheld even if it is unreasonable and arguably wrong so long as it is not arbitrary and capricious. As the NCAA tells it, Whitwell—a University of Mississippi School of Law graduate and an elected official—failed to apply the standard as it was intended.

Mindful that interlocutory appeals are disfavored since the record is incomplete, the NCAA insists that the Supreme Court ought to review the matter because of the case’s broader implications and the timing of the situation.

The NCAA explains that, as a membership organization, it has a contractual duty to “ensure a level playing field among” all competing schools. The NCAA suggests it must seek appeals to block courts from “intervening in NCAA eligibility decisions to provide special treatment to favored athletes.” If trial judges meddle with the NCAA’s administration of eligibility rules, the NCAA’s petition argues, that meddling poses an “existential threat to the NCAA’s administration of collegiate sports.”

To corroborate that point, the NCAA warns that unless Chambliss is deemed ineligible, there will be a “flood of litigation” involving athletes whose schools are denied medical waivers. The NCAA points out that UVA quarterback Chandler Morris recently sued the NCAA in Virginia in hopes of obtaining a seventh year of eligibility, and the basis of his case is the denial of a medical waiver.

The NCAA also advises the state Supreme Court that the risk of “spillover effect” has been borne out through the aftermath of former Vanderbilt quarterback Diego Pavia’s eligibility litigation against the NCAA to play a sixth season of college football.

“Since Pavia,” the NCAA writes, “over 60 lawsuits by over 100 student-athletes have raised similar challenges.” This litigation, the NCAA maintains, has caused “uncertainty” as to NCAA eligibility.

The NCAA knows that if Whitwell’s injunction isn’t lifted, the case is effectively over: The injunction will let Chambliss play for Ole Miss in 2026 and then he’ll move on to the NFL or other pursuits. Whether Chambliss would prevail in a trial, which might not be scheduled until 2027 or beyond, could be rendered irrelevant if Chambliss decides to drop the case after the 2026 season.

Chambliss v. NCAA is a reminder of the unique features of the post-House settlement world. It now pays to stay in school, given that athletes can receive full athletic scholarships, NIL deals and direct payments from their schools through revenue shares. According to ESPN, Chambliss could earn about $6 million at Ole Miss if he plays there this fall.