Written By: Kyle Gabri
NCAA Policy Restricting the Number of Paid Coaches
From 1992 to July 2023, the NCAA and its member institutions agreed to restrict the number of paid coaching positions in Division I athletics. Although the NCAA instituted a cap on paid positions, certain teams were allowed to have one volunteer coach who was unpaid and ineligible to receive benefits. Schools that violated this policy were penalized by the NCAA. However, this bylaw was repealed by the NCAA in January 2023. When this decision became effective on July 1, 2023, it eliminated volunteer coaching positions and increased the availability of paid positions to include those previously designated as volunteer.
Argument Presented by Division I Volunteer Coaches
This action, which was filed in March 2023, alleged that the NCAA had violated Section 1 of the Sherman Act. Section 1 of the Sherman Act, which states that “every contract, combination in the form of trust or otherwise, or conspiracy, in restraint of trade or commerce among the several states, or with foreign nations, is declared to be illegal,” prohibits various conduct, including price-fixing. In this action, it is alleged the NCAA colluded “through a binding NCAA bylaw, to fix the compensation of an entire category of coaches at zero.” The bylaw at issue in this complaint is one that imposed a limit on paid coaching positions and prohibited volunteer coaches from receiving compensation. The complaint alleged that individuals hired as volunteer coaches performed duties similar, if not the same, to those who held paid positions. The complaint also stated that these volunteer coaches often worked full-time, with no salary or benefits.
Impact on Coaching Opportunities in Division I Athletics
The NCAA’s decision to settle this lawsuit may raise mixed opinions. On one hand, it has provided thousands of former volunteer coaches with an opportunity to receive back pay for their services. Since many of these individuals worked full-time, without receiving any compensation or benefits, one could argue this settlement will make these coaches whole and give them what they are rightfully owed. However, others may argue these coaches accepted an unpaid position and, therefore, are not entitled to any compensation or benefits.
Regardless of which position one takes, this settlement may have permanently eliminated volunteer coaches in college athletics. Although the NCAA has increased the availability of paid coaching positions, requiring compensation may cause these roles to be more competitive and filled by coaches with prior experience. As a result, someone looking to enter the coaching profession may struggle to find an opportunity that was previously available through a volunteer position. While many schools offer graduate assistant roles, which provide valuable experience, these positions require enrollment at the institution. It is also important to recognize that NCAA institutions have different budget requirements, and some schools may be unable to afford a large coaching staff. Therefore, turning volunteer roles, which required no compensation from NCAA institutions, into paid positions may lead to greater coaching vacancies due to monetary concerns.
Sources:
15 U.S.C.A. § 1 (West).
Kat Black, NCAA Reaches $303M Settlement Agreement With ‘Volunteer’ Division 1 Sports Coaches, Law.com (Nov. 14, 2025, 7:26 PM).
Mike Scarcella, NCAA Agrees to $303 Million Settlement With Unpaid College Coaches, Reuters (Nov. 11, 2025, 10:04 AM).
Paula Lavigne, NCAA Agrees to $303 Million Settlement With Volunteer Coaches, ESPN (Nov. 11, 2025, 9:48 AM).
The Associated Press, NCAA Agrees to Pay Volunteer Coaches Total of $303 Million Under Proposed Settlement, AP News (Nov. 12, 2025, 8:01 PM).

