By: Jonathan Tunney
March 19th, 2025

Photo Credit: KSEE
Vanderbilt Quarterback Diego Pavia will be returning to Nashville for his 6th season of college football after challenging an NCAA rule stating that NAIA and Junior College playing time counts against NCAA eligibility. Pavia argued that the rule violated the Sherman Antitrust Act, and the US District Court of Middle Tennessee agreed. The court granted Pavia a temporary one-year injunction, giving him an extra year of eligibility while the NCAA appeals the ruling. The NCAA extended this injunction to all players who played at a non-NCAA institution and are seeking an additional year of eligibility while awaiting the results of their appeal.
Given the initial results of the case, and recent negative outcomes for the NCAA in other court cases, it is highly likely that the appeal will be unsuccessful, and the ruling will stand. If this is the case, NAIA and Junior College playing time will no longer count against a player’s NCAA eligibility. This is a massive opportunity for players, as it is rumored that Pavia’s 2025-2026 campaign could be worth up to $1M in NIL. However, the ruling also opens up another potential loophole: Could junior colleges become the minor leagues of major college athletics?
I envision a developmental system much like minor league baseball, let’s use the University of Michigan football team as an example of how this would look in practice. Player A gets recruited to the University of Michigan to play football and is immediately sent to the school-affiliated junior college. At junior college, Player A will learn Michigan’s system, train with college-level strength coaches, and develop their game. Additionally, Player A now has the opportunity to ease into college life with junior college classes in a smaller atmosphere. After 2 years, or before then if Player A is ready, they get called up to the University of Michigan football team, with 4 full years of eligibility remaining. This system is similar to the minor leagues in Major League Baseball, or how junior hockey relates to NCAA hockey, but with junior college education added in as well. With similar systems already in place in other sports, why can’t it happen in college football?
This system would give players up to two full years of training and development before even joining the FBS team. This would greatly increase the quality of the on-the-field product, and help teams develop more depth after the controversial roster cuts. For instance, football teams can now only carry 105 scholarship players instead of 135 scholarship and non-scholarship players, and NCAA baseball teams can now only carry 34 players instead of 40. This would give teams utilizing the junior college system a massive advantage regarding talent development over those who don’t. How would other teams compete? By affiliating with their own junior college, of course.
I can already hear the critics: “Players today would never do that, they’d transfer immediately!”, they chant in unison. First, there would be plenty of star players who would go straight to the FBS team. Even if the junior college is only used to develop depth pieces, this will still give teams a massive advantage. Second, yes there will be a lot of transfers while the system is first implemented, but there are already many, many transfers. As of 2023, 20.5% of all FBS rosters were made up of transfer players. Third, if a player goes to a team’s junior college and can’t cut it, then they can transfer without using any of their NCAA eligibility.
How much money would it cost to buy a junior college? According to my research, it varies greatly. After filing for bankruptcy, the College of Saint Rose in Albany New York sold its campus for $35M at auction in 2018. In 2024, Birmingham-Southern College attempted to sell its 192-acre campus for $65M due to financial difficulties, but the deal fell through. Finally, in January 2025, the Alamo Colleges District in San Antonio, Texas proposed a $987M bond to build new junior college infrastructure and facilities.
This evidence makes me think that building a new junior college or purchasing one outright would be untenable. The most logical way to make the junior college system a reality is for college athletic departments to subsidize junior college athletic departments with yearly payments in exchange for exclusive affiliation. In 2019, East Mississippi Community College (from season 1 of Last Chance U on Netflix) spent $2.03M on athletics, with the department operating at a $1.14M deficit. In 2024, the University of Michigan Athletic Department grossed over $238M in revenue. This is a no-brainer for both sides. FBS programs could use junior colleges to supercharge player development and create better depth, while junior colleges could kiss all their budget problems goodbye.
What does the perfect junior college affiliate look like? First, it should be somewhere warm. California, Arizona, Nevada, Texas, and Florida all come to mind. Why waste money building or maintaining a costly indoor practice facility? Elite JUCO programs in these regions find themselves as the belle of the ball, with college football powerhouses competing in a bidding war for such schools. Second, the school shouldn’t be in a major metropolitan area or right next to the affiliated FBS school. The goal is development, not distraction. Finally, players should take the majority of classes online. Many college football players already take the majority of their classes online, this will allow players to move flexibly if they are called up to the FBS team mid-semester.
The proposed junior college system is a phenomenal opportunity for college athletes academically as well. Players who stay at junior college for two full years can leave with an associate's degree if they graduate on time. They can choose to pursue a traditional undergraduate degree once reaching the FBS team or put their credits to use to graduate early, and even pursue graduate or master's programs faster. Finally, this system won’t interfere with players’ NFL draft eligibility. Currently, a player must be three years removed from their high school graduation to be eligible. This should stay the same, regardless of if one or two of those years happen at the junior college level.
If the NCAA’s appeal is unsuccessful, purchasing or affiliating with a junior college represents a massive potential competitive advantage due to enhanced player development. It’s only a matter of time before an institution figures this out and pulls the trigger. Once they do, and other schools see the corresponding success, a mad dash will ensue.
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