The NCAA wants to continue litigating an eligibility lawsuit filed against the organization by former Memphis football receiver Cortez Braham, even with Braham preparing for the 2026 NFL Draft.
After the 2025 season, Braham's lawyers filed a motion to dismiss the NCAA's appeal of the preliminary injunction that made Braham eligible to play for Memphis in 2025.
The case, they argued, should be dismissed because the issue was moot, with the season — and Braham's collegiate career — finished.
But the NCAA disagreed. And now Memphis could be directly affected by the outcome of the case.
In a Feb. 6 filing, the NCAA argued the issue was not moot. Lawyers for the NCAA wrote in the filing that one of the reasons they wanted to continue with the case was the fact that the injunction stops them from enforcing the "rule of restitution" against Memphis.
Though the lawsuit was filed before Braham even committed to Memphis (he played at Nevada in 2024 and did not choose to transfer to Memphis until after the injunction was granted in July), this filing is the first time Memphis has been tied to the lawsuit in any way.
The NCAA listed four "potential" actions that it could take against Braham and Memphis if the injunction was lifted:
- Vacate or strike individual records or performances by Braham
- Vacate team victories from the season (Memphis went 8-5)
- Force Braham to return any awards he won during the season
- Assess a "financial" penalty to Memphis
Memphis did not immediately respond to a request for comment.
In a response filed on the same day in a separate eligibility lawsuit (Martinson v NCAA), the NCAA made the same argument. In that case, NCAA lawyers wrote they wanted to enforce the rule of restitution against San Diego State, where defensive lineman Tatuo Martinson played in 2025 after two seasons at UNLV.
The filing does not say what exactly the NCAA would do in this situation. In order for the NCAA to be able to assess penalties against Memphis, a judge would have to deny Braham's motion to dismiss the lawsuit, and the NCAA ultimately would have to prevail in the next phase of the case.
Oral arguments are currently set for March.
NCAA attorneys cited a Nov. 13 letter sent to NCAA institutions where the NCAA Board of Governors essentially asked athletic departments not to take players who had become eligible because of court actions.
"Coaches and other athletics department officials who encourage these lawsuits, and even support them on the premise that it is to benefit only one student-athlete, are undermining the very rules their schools have voted to approve and abide by, and are depriving future student-athletes of meaningful opportunities to compete," the letter said.
Braham's journey to Memphis was unique. He played two seasons at Hutchinson Community College in Kansas before attempting to transfer to West Virginia, but he was 0.1 GPA points away from meeting the admissions criteria. He spent another year at Hutchinson to work on his grades, then transferred to West Virginia in 2022. He spent two seasons there before transferring to Nevada, where he played a significant role in 2024.
After the 2024 season, Braham asked Nevada to file a waiver with the NCAA on his behalf, but attorneys wrote in multiple legal filings that Nevada refused to do so. Braham sued the NCAA, arguing he should get a final year of eligibility, and a judge granted a preliminary injunction.
Braham's case is notably different than the much more well-publicized case involving former Vanderbilt quarterback Diego Pavia because it hinged on the NCAA's five-year clock and not the fact that Braham began his career at the junior college level.
Braham filled a major gap for the Tigers in 2025. They had entered training camp without a clear-cut top receiver, and though he joined the team just two weeks before the season started, he quickly took on the role. He caught 63 passes for 889 yards and four touchdowns during the season, when the lawsuit was still active.
"I feel like it hasn't really hit me on that aspect," Braham said during the season. "I just take it day by day and things like that. I'm hoping that it does help other college athletes in my situation. Because I have friends and things like that that's going through the same things. I'm hoping that it does help a lot and it does change. But I just keep my head down, just keep working."
The NCAA has faced a seemingly never-ending stream of eligibility lawsuits in the past few years. On Feb. 12, a Mississippi judge granted Ole Miss quarterback Trinidad Chambliss an additional year of eligibility. A ruling is expected soon on a similar challenge for Tennessee quarterback Joey Aguilar as he seeks another year of eligibility.
Reach sports writer Jonah Dylan at [email protected] or on X @thejonahdylan.
This article originally appeared on Memphis Commercial Appeal: In Cortez Braham legal case, NCAA wants 'restitution' against Memphis