IDS Thursday, February 26, 2026
Indiana Daily Student | idsnews.com
NCAA threatens rule of restitution against Indiana Safety Louis Moore played the entire 2025 season after suing for his eligibility By Nathan Shriberg
naashri@iu.edu | @NShriberg
The NCAA has threatened to invoke the “rule of restitution” against Indiana University and former Indiana safety Louis Moore in his ongoing eligibility lawsuit. According to a response filed in Texas’ Fifth Court of Appeals, the NCAA believes its Division I Board of Directors is entitled to seek restitution, “if they so choose.” Listed possible actions include vacating Moore’s individual performances and repealing team victories, “including the national championship.” Bylaw 12.9.4.2 of the 2025-26 NCAA Division I Manual states if a player ruled ineligible by the NCAA is allowed to participate by a court order that is later “voluntarily vacated, stayed, or reversed,” the Board of Directors is permitted to take action against the institution “in the interest of restitution and fairness.” Possible actions include: • Vacating individual and team records and performances • Declaring the institution ineligible for NCAA Championships in the sport and season that the ineligible student-athlete played in “It is draconian,” Boise State University assistant professor Sam Ehrlich said. “It really kind of disincentivize(s) athletes from being able to seek judicial intervention.” After suing for his eligibility, Moore played the entire 2025 season on a series of court rulings that culminated in a temporary injunction being ordered Sept. 24 that kept him eligible for the rest of the season. An Indiana Athletics spokesperson said Moore was “cleared to play pursuant to a decision made by the courts.” Ehrlich, an expert in sports and antitrust law, noted that judges have identified “the rule goes far beyond what it’s intended to do” and encourages schools to “go against court orders.” A non-jury trial in the district court was originally scheduled for Jan. 29, but court records indicate the trial was canceled. A notice of nonsuit was filed by Moore’s attorneys Jan. 20, the day after Indiana football won the national championship. The nonsuit was granted eight days later, ordering that all of Moore’s claims against the NCAA are “dismissed without prejudice.” The decree officially closed Moore’s case at the district level, but recent developments in the appellate court have reignited concerns over its fallout. The NCAA has argued that the injunction — which granted Moore eligibility and enjoins the NCAA from invoking the “rule of restitution” — was voluntarily vacated by the nonsuit, freeing the NCAA Board of Directors to invoke the rule. While it remains unclear if the NCAA intends to penalize Indiana and other schools involved in similar cases, the argument represents the next step toward reaching an appellate ruling. Former University of Memphis wide receiver Cortez Braham Jr. and former San Diego State University defensive lineman Tatuo Martinson also sued for
their eligibility and played the 2025 season under an injunction. However, Braham and Martinson did not file a notice of nonsuit in the district court. “What’s going on in these three cases isn’t even necessarily about the rule of restitution,” Ehrlich said. “I think it’s just the NCAA really wants an appellate ruling.” The NCAA seeks an appellate ruling that says its eligibility rules are legal and can’t be challenged under antitrust law. Similar cases have struggled to reach an appellate ruling because of the nature of the timing of the lawsuits with regard to when the player seeks eligibility.
“The appellate courts are going to have to rule on the merits. And I think that’ll say a lot about the enforceability of these rules moving forward.” Sam Ehrlich, Boise State University assistant professor
As players initiate lawsuits the same year they seek to play, injunctions are frequently granted for those seasons because the courts determine that withholding eligibility would constitute irreparable harm — one of the factors in determining whether an injunction is necessary. Moore transferred to Indiana following the 2024 season with the intention to play his final year with the Hoosiers. However, prior to the beginning of the year, the NCAA denied his eligibility waiver. Moore began his collegiate career at Navarro Community College from 2019-21, and the NCAA attempted to count his junior college years against his NCAA eligibility. In the wake of a federal judge in Tennessee granting former Vanderbilt University quarterback Diego Pavia an injunction to play the 2025 season, the NCAA issued a blanket eligibility waiver to players in similar situations, which Moore believed included him. In each case, the injunctions enjoined the NCAA from enforcing the “rule of restitution” for complying with the order. The NCAA argued Braham’s case was not moot, and specifically that being prevented from enforcing the “rule of restitution” was reason to keep it going. In a Feb. 9 filing, the NCAA’s attorneys stated they could vacate or strike individual records or performances, vacate team victories, force Braham to return any awards he won during the season or assess a financial penalty to the University of Memphis. In all three cases, the NCAA contends the injunctions should never have been issued, but the presence of the nonsuit makes Moore’s case unique. As the Braham and Martinson cases move closer to rulings on their motions to dismiss, college athletics seeks clarity, and Indiana football’s historic 2025 season could hang in the balance. “The appellate courts are going to have to rule on the merits,” Ehrlich said. “And I think that’ll say a lot about the enforceability of these rules moving forward.”
INSIDE
Spring Sports Guide
IU admissions portal language sparks concern
Faculty accuse IU of deterring applicants with misleading admissions language By Zoe Reed
reedzoe@iu.edu
Indiana University’s Common App admissions portal now tells incoming students “no new admissions will be offered” for dozens of suspended majors being reconfigured under state law. This includes degrees in gender studies, Earth science and more. Some faculty say the notice misleads students and hinders humanities and language enrollments. The portal displays a “Program Suspension Notice” for major programs affected by language in the state budget bill requiring universities to eliminate programs that don’t meet minimal enrollment quotas. Bachelor’s programs must have had an average of 15 graduates annually over the past three years to not be counted as a low-enrollment program or ask for an exemption from the Indiana Commission for Higher Education. Instead of seeking exemptions, IU voluntarily eliminated, suspended or merged 249 low enrollment programs from IU campuses on July 1, 2025. At IU Bloomington, 116 degree programs faced changes. Out of these 116 degrees, 22 were eliminated and 31 will be suspended after currently-enrolled students complete their programs. Another 63 were suspended with the goal to either consolidate or merge with other departments, only after being approved by the ICHE. The notice on IU’s admissions portal warns applicants that majors marked with an asterisk are suspended for spring 2026 admissions and that no new admissions will be accepted. Students interested in these marked majors can indicate their “major interest(s)” by selecting them as a first or second intended major. The university can then share information about “related courses and available alternatives” and “potential future academic options (subject to necessary approvals).” An earlier version of the Common Application allowed students to select suspended programs as their “intended major,” but this was updated to the “major interests” option after Feb. 11. Both versions state no new admissions will be offered for suspended programs.
JONATHAN FREY | IDS
A sign reads "Save the Languages at IU!" on Aug. 21, 2025, in the Global and International Studies Building. IU voluntarily eliminated, suspended or merged 249 low enrollment programs from IU campuses on July 1, 2025.
Some high school seniors and parents in the application process could interpret the notice as suggesting all their interests are not available at IU, Deborah Cohn, a Spanish and Portuguese professor at IU, said. Cohn said the notice should state more clearly that IU still offers these fields of study, even if they may be consolidated or merged as part of the ongoing restructuring process. “They could have said something more userfriendly, such as, ‘We are currently in the process of applying to offer these, and here’s a contact person,’” Cohn said. IU spokesperson Mark Bode wrote in an email that the application form allows students to show interest in suspended programs and that the admissions team will reach out to students with alternatives and updates. “At the launch of this year’s admissions cycle, the IU Admissions team worked to make sure prospective students could indicate areas of interest on their applications, including areas corresponding to suspended programs,” Bode wrote. “The site noted that registering interest in these programs would enable IU to share information on relevant future academic options.” In February, the ICHE approved new reconfigured programs, IUB Chancellor David Reingold said during a Bloomington Faculty Council meeting Feb. 10. In the meeting, Reingold said that confusing language in the university’s Common
App application would be updated that day or the next. “The enrollment management staff is working to communicate with currently admitted students in coordination with the College and changes in the application are underway,” Reingold said. At the Feb. 10 BFC meeting, Reingold addressed faculty worries that enrollment for affected programs is and will continue to go down, telling attendees that applications, admissions and deposits for affected programs are all higher than last year. Bode clarified Reingold’s statement in an email to the Indiana Daily Student on Feb. 19, confirming that overall applications, admits and deposits for the affected degree programs have increased from previous cycles. “A definitive assessment of major-specific enrollment trends will be available once the updates to academic structure and assignment of the appropriate program/plan codes to the student records have been completed,” Bode wrote. Nicolas Valazza, the interim director of undergraduate studies at IU, helped organize the Save the Languages at IU initiative, a faculty-led group formed to oppose cuts to language programs. He said he received a message from a parent of a prospective student confused about the application a couple weeks ago. “The admission application was basically saying that they were suspended and no new student would be admitted,” Valazza said.
“So we found this very concerning.” Valazza said students planning to major in suspended studies might see the portal message and choose to attend elsewhere. But since those potential applicants never contacted the departments, faculty have no way to track how many students were deterred. Cohn said departments have been fielding confused calls from incoming students and their parents since the summer. "The lack of clarification is going to have caused damage to the number of students who were interested in these programs,” Cohn said. “That were given the sense that they don’t even exist anymore.” For Valazza, the issue is urgent. He said clear communication needs to be sent to all incoming students rectifying the information. Beyond enrollment concerns, Valazza said the issue threatens IU’s core identity and reputation. “The reputation of IU Bloomington is based, on (a) largest extent, on its liberal arts tradition, its humanities, foreign languages, those are our strength,” Valazza said. “I’m still optimistic that the administration has IU in its heart.” Both Valazza and Cohn said students and parents shouldn’t give up on IU because of the portal language alone. “Don’t stop with that information,” Cohn said. “Go and reach out to the departments that you and your children are interested in. Get the information, because the information is out there.”
IUB chancellor speaks on freedom of speech at IUSG Q&A By Elizabeth Schuth ekschuth@iu.edu
IU Bloomington Chancellor David Reingold held a Q&A with IU Student Government Feb. 23, addressing freedom of speech concerns, IU President Pamela Whitten’s raise and non-traditional students. These were some of the key topics: Future of the IDS and freedom of speech An IUSG representative questioned IU’s plans regarding potential censorship of diversity, equity and inclusion language. The university closed its DEI office in May following federal and state efforts to curtail DEI in government and education. In response to the repre-
JIMMY RUSH | IDS
Virginia Hojas Carbonell (left), David Reingold (middle) and Noah Stoffman (right) are pictured during a Bloomington Faculty Council meeting Feb. 10, 2026, inside Presidents Hall in Bloomington. Reingold attended a Q&A with IU Student Government on Feb. 23.
sentative’s question, Reingold referred to the university’s recent resolution adopting the Chicago Principles on campus as guidelines to
student free speech protections. The Chicago Principles are a set of freedom of speech values established
by the University of Chicago and adopted by over 100 universities. SEE CHANCELLOR, PAGE 4