An Ohio federal judge Tuesday denied a college basketball player's request to consider letting him play a sixth season, upholding an NCAA rule limiting competition to four seasons in a five-year span and describing the policy as reasonable.

U.S. District Judge James L. Graham determined that granting Donovan "Puff" Johnson's motion for a hearing would be futile because the case "does not implicate competition" under antitrust laws.

"The facts proffered in support of the motion, if assumed to be true, would not alter the court's conclusion that this case involves an economic loss incurred by a single individual who is impacted by a reasonable rule of athletic eligibility," Judge Graham wrote in a two-page opinion and order.

Johnson, currently enrolled at Ohio State University, is one of several college athletes challenging the league's eligibility bylaws largely rooted in keeping them at Division I programs for no more than five years. The athletes have said the restrictions often unjustly deny them opportunities for compensation, and they have relied on antitrust laws to argue against the five-year rule and allege it is an anticompetitive restraint on trade.

Johnson sued the NCAA Nov. 5, after his request for a medical hardship waiver allowing him to play in the 2025-2026 season was denied. He had competed for three seasons, starting in 2020, at the University of North Carolina, and then two more seasons, from 2023 to 2025, at Penn State University.

He asserted that his injuries during the 2024-2025 season at Penn State should be enough reason to give him an NCAA waiver exempting that season from its rule and making the current season his final year of competition.

However, the association determined that Johnson had surpassed the threshold of games played that would have exempted the last season from his eligibility window. It did not count the 2020-2021 season, in which a waiver was granted to all athletes because of the COVID-19 pandemic, toward the eligibility period.

On Nov. 11, 2025, Judge Graham turned down Johnson's bid for an injunction allowing him to play, finding the student was not likely to succeed on the merits of his case.

A spokesperson for Amundsen Davis LLC, the firm representing Johnson, told Law360 its attorneys had read Judge Graham's decision and were "working with our client to determine our next steps.''

Other athletes have challenged a similar NCAA eligibility bylaw regarding injuries, including the "redshirt rule" permitting them to sit out a season and still compete for four years within the five-year window.

University of Washington football player Jacob Manu sued in Washington federal court in October, alleging the rules forced him to count this season toward his eligibility limit despite being injured. Manu's suit was transferred last month to Tennessee federal court, where another putative class action attempting to overturn the redshirt rule regarding injured athletes was filed earlier this year.

Still other suits have pushed back against eligibility rules limiting players' time to compete after transferring from non-Division I institutions. Johnson's suit referenced Vanderbilt football player Diego Pavia, who scored an injunction to play this season. Concurring opinions in the Sixth Circuit decision upholding Pavia's injunction found the NCAA eligibility rules deserved the same antitrust scrutiny its compensation rules had received.

Representatives of the NCAA did not immediately respond to a request for comment.

Johnson is represented by Larry H. James and Christopher R. Green of Amundsen Davis LLC.

The NCAA is represented by Keith Shumate of Squire Patton Boggs LLP and Rakesh Kilaru of Wilkinson Stekloff LLP.

The case is Johnson v. National Collegiate Athletic Association, case number 2:25-cv-01288, in the U.S. District Court for the Southern District of Ohio.