A volunteer coach “does not receive compensation or remuneration from the institution’s athletics department or any organization funded in whole or in part by the athletics department,” and each member institution may use the services of one volunteer coach in applicable sports. NCAA Division I Bylaws 11.7.6 and 11.01.6 (2021–22).

This bylaw language forms the basis of a proposed $303 million settlement in Ray et al. v. NCAA, No. 1:23-cv-00425 (E.D. Cal.). Plaintiffs characterized the 31-year restriction as a horizontal wage-fixing agreement hiding in plain sight; the NCAA maintained that legitimate procompetitive purposes justified the rule. The settlement resolves these competing claims without a decision on the merits, but the case nonetheless marks a notable chapter in antitrust scrutiny of labor market restraints.

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