A federal judge has dismissed former college swimmer Riley Gainesβ lawsuit against the National Collegiate Athletic Association (NCAA), ending the case at the district court level after ruling that the plaintiffs had not established that the NCAA receives federal financial assistance required for a Title IX claim.
U.S. District Judge Tiffany R. Johnson of the U.S. District Court for the Northern District of Georgia granted the NCAAβs motion for summary judgment on the remaining Title IX claims.
Gaines and the other plaintiffs have said they intend to appeal the decision to the U.S. Court of Appeals for the 11th Circuit.
The decision does not resolve the broader policy debate over transgender participation in college sports.
Instead, the ruling centered on a legal question: whether the NCAA itself falls within Title IX because it receives federal financial assistance.
Key Facts About the Riley Gaines NCAA Lawsuit
- Plaintiff: Riley Gaines and other current and former female collegiate athletes
- Defendant: National Collegiate Athletic Association (NCAA)
- Judge: U.S. District Judge Tiffany R. Johnson
- Court: U.S. District Court for the Northern District of Georgia
- Lawsuit filed: March 2024
- Main law involved: Title IX
- Central legal issue: Whether the NCAA is a recipient of federal financial assistance
- Recent ruling: The remaining Title IX claims were dismissed
- Next step: Gaines and other plaintiffs have indicated they plan to appeal
- Appeal court: U.S. Court of Appeals for the 11th Circuit
Why Was Riley Gainesβ NCAA Lawsuit Dismissed?
The central issue was not simply whether the NCAA had adopted a transgender-athlete participation policy.
The court focused on whether Title IX could legally be applied to the NCAA in the circumstances presented by the plaintiffs.
Title IX generally prohibits sex discrimination in an education program or activity receiving federal financial assistance.
The Supreme Court has previously considered whether the NCAA itself is subject to Title IX.
In NCAA v. Smith, the Supreme Court held that receiving dues from member institutions that receive federal funds was not, by itself, enough to subject the NCAA to Title IX.
In the Gaines case, the plaintiffs attempted to establish a different connection between the NCAA and federal money.
Their legal team pointed to a research relationship involving the NCAA, the U.S. Department of Defense and Indiana University.
The plaintiffs argued that the arrangement demonstrated a sufficient connection between the NCAA and federal financial assistance.
Judge Johnson rejected that argument, finding that the evidence did not establish that federal funds were received by the NCAA itself.
Reporting on the ruling says the judge found that the Defense Department’s money went to Indiana University and other research participants rather than to the NCAA.
As a result, the court concluded that the plaintiffs’ Title IX claims could not proceed against the NCAA on the evidence presented.
What Did Riley Gaines and the Other Athletes Claim?
Gaines and more than a dozen other current and former female collegiate athletes filed the lawsuit in 2024.
The plaintiffs challenged the NCAA’s former policy governing transgender participation in women’s college sports.
They argued that the policy violated their rights under Title IX and alleged that transgender athletes’ participation affected their competitive opportunities and privacy.
The lawsuit was closely associated with the 2022 NCAA Division I Women’s Swimming and Diving Championships in Atlanta.
Gaines, who was competing for the University of Kentucky, tied transgender University of Pennsylvania swimmer Lia Thomas for fifth place in the women’s 200-yard freestyle final.
Thomas also won the women’s 500-yard freestyle at the championship.
The 2022 championships subsequently became a major focus of the national debate over transgender participation in women’s sports.
Lia Thomas and the 2022 NCAA Swimming Championships
Lia Thomas competed for the University of Pennsylvania at the 2022 NCAA championships.
Thomas won the women’s 500-yard freestyle, becoming the first openly transgender athlete to win an NCAA Division I individual championship, according to reporting on the case.
Gaines and Thomas also tied for fifth place in the 200-yard freestyle final.
Gaines and other plaintiffs later argued that the NCAA’s policies disadvantaged female athletes and raised concerns involving competition and locker-room privacy.
Those allegations formed part of the broader lawsuit, but the latest ruling did not determine whether every underlying allegation about the former NCAA policy was valid.
Instead, the court’s decision turned on whether the NCAA was subject to Title IX based on federal financial assistance.
What Is Title IX?
Title IX is a federal civil-rights law that prohibits sex discrimination in education programs or activities receiving federal financial assistance.
The statute is therefore important in disputes involving federally funded schools and educational programs.
However, the fact that a university receives federal funding does not automatically mean every separate organization connected to that university is itself a recipient of federal financial assistance.
That distinction was critical in the Gaines lawsuit.
The Supreme Court’s 1999 decision in NCAA v. Smith is particularly relevant because the Court considered whether the NCAA could be subjected to Title IX merely because its member institutions received federal funding and paid dues to the association. The Court rejected that theory.
The Gaines litigation presented a different alleged funding connection involving an NCAA research relationship, but Judge Johnson ultimately found that the evidence did not establish the NCAA as a recipient of federal financial assistance.
Did the Judge Rule on Whether the NCAAβs Former Policy Violated Title IX?
Not in the broad sense suggested by the underlying political and sports debate.
The key issue decided at this stage was whether the NCAA was subject to Title IX under the federal-funding requirement.
The court’s conclusion that the NCAA was not shown to be a recipient of federal financial assistance prevented the plaintiffs’ Title IX claims from proceeding.
That distinction is important. The ruling should not be described as a judicial finding that all claims concerning transgender participation in college sports are legally invalid.
It was a decision about the legal applicability of Title IX to the NCAA under the evidence presented in this case.
NCAAβs Transgender Athlete Policy Has Since Changed
Another important development is that the NCAA policy challenged in the lawsuit is no longer in effect.
On February 6, 2025, the NCAA announced a revised transgender student-athlete participation policy.
Under the policy currently published by the NCAA, athletes assigned male at birth may not compete on NCAA women’s teams, although they may practice with women’s teams and receive certain benefits associated with practice.
The policy also contains rules concerning athletes assigned female at birth who have begun testosterone therapy.
The NCAA said the change followed the Trump administration’s executive order concerning women’s sports and was intended to establish a uniform national eligibility standard.
Consequently, the NCAA’s present eligibility rules differ substantially from the policy challenged by Gaines and the other plaintiffs.
What Did the NCAA Say?
Following the ruling, an NCAA spokesperson said the organization is committed to investing in women’s sports and said the NCAA is complying with the Trump administration’s executive order concerning women’s sports.
The organization did not need the court to determine the legality of its former transgender participation policy for the latest ruling because the case was resolved on the Title IX federal-funding issue.
Riley Gaines Plans to Appeal
Gaines has said that the ruling will not end the legal challenge.
She and the plaintiffs have indicated that they intend to appeal the district court’s decision to the U.S. Court of Appeals for the 11th Circuit.
Reporting on the ruling indicates that the plaintiffs have 30 days to file a notice of appeal.
An appeal would give the plaintiffs another opportunity to challenge the district court’s interpretation of the NCAA’s relationship to federal financial assistance.
The appeals process could therefore determine whether the Title IX question receives further consideration in federal court.
Riley Gaines vs. NCAA Lawsuit Timeline
2022:
Riley Gaines competes against Lia Thomas at the NCAA Division I Women’s Swimming and Diving Championships in Atlanta. Thomas wins the 500-yard freestyle, while Gaines and Thomas tie for fifth in the 200-yard freestyle.
March 2024:
Gaines and other current and former female collegiate athletes file their lawsuit against the NCAA. The case is filed in the Northern District of Georgia.
2025:
The NCAA changes its transgender student-athlete participation policy, restricting women’s competition to athletes assigned female at birth under its new policy.
September 2026:
Judge Tiffany R. Johnson grants the NCAA’s motion for summary judgment on the remaining Title IX claims and dismisses the case at the district court level.
Next:
Gaines and the other plaintiffs have indicated that they intend to appeal to the 11th Circuit.
What Happens Next in the Riley Gaines NCAA Lawsuit?
The immediate next step is an appeal.
If the plaintiffs file their notice of appeal within the applicable deadline, the 11th Circuit will become the next federal court to consider the dispute.
The appeal could focus on the question of whether the evidence surrounding the NCAA’s research relationships and funding arrangements was sufficient to establish that the association receives federal financial assistance for purposes of Title IX.
The appellate court could affirm the district court’s ruling, reverse it, or otherwise alter the legal analysis.
The outcome of any appeal should therefore be distinguished from the current district court judgment.
For now, the September 2026 decision remains the ruling at the trial-court level.
Frequently Asked Questions
Why was Riley Gaines’ lawsuit against the NCAA dismissed?
The federal judge concluded that the plaintiffs had not established that the NCAA receives federal financial assistance, a requirement for applying Title IX to the organization in this lawsuit.
Will Riley Gaines appeal the NCAA lawsuit ruling?
Yes. Gaines has publicly indicated that she and the other plaintiffs intend to appeal the decision to the U.S. Court of Appeals for the 11th Circuit.
What was the Riley Gaines lawsuit about?
The lawsuit alleged that the NCAA violated Title IX through its former transgender-athlete participation policies and argued that those policies affected female athletes’ competitive opportunities and privacy.
Does the NCAA still allow transgender women to compete in women’s sports?
The NCAA’s current published policy, effective February 6, 2025, states that a student-athlete assigned male at birth may not compete on an NCAA women’s team. Such athletes may practice with women’s teams and receive certain benefits associated with practice.
What happened between Riley Gaines and Lia Thomas?
Gaines and Thomas competed against each other at the 2022 NCAA Division I Women’s Swimming and Diving Championships. They tied for fifth in the 200-yard freestyle final, while Thomas won the 500-yard freestyle.
Does the ruling mean the court decided transgender athletes cannot compete in women’s college sports?
No. The September 2026 ruling primarily concerned whether the NCAA was subject to Title IX because of federal financial assistance. The NCAA’s own participation rules had already changed in 2025.
Bottom Line
The Riley Gaines NCAA lawsuit has been dismissed at the federal district court level, but the legal dispute may not be over.
Judge Tiffany Johnson’s ruling focused on whether the NCAA could be treated as a recipient of federal financial assistance under Title IX.
The court concluded that the evidence presented by the plaintiffs did not establish that connection.
Gaines has indicated that she plans to appeal, meaning the 11th Circuit could eventually examine the federal-funding issue.
Meanwhile, the NCAA has already replaced the transgender participation policy at the center of the lawsuit.
Its current policy restricts women’s competition to athletes assigned female at birth, making the NCAA’s present rules materially different from the policy challenged in the 2024 lawsuit.
The next significant development will therefore be whether the plaintiffs formally appeal and, if so, how the 11th Circuit addresses the Title IX question.
