Anyone who follows college football probably knows about the Nico and Madden Iamaleava sagas. Nico Iamaleava was a 2024-25 playoff star quarterback for Tennessee with a Name, Image and Likeness (“NIL”) package worth $2.4 million, but ultimately unhappy. He announced on April 20, 2025, that he would be transferring to the UCLA Bruins (which, incidentally, caused the Bruins’ QB to transfer to Tennessee). According to media reports, Nico Iamaleava will get more than $1.5 million in NIL payments from UCLA, but less than the amount that Tennessee was set to pay him in 2025-26. See the ESPN media report here.

Madden Iamaleava was originally pledged to UCLA, but switched at the last minute to Arkansas during the 2024 recruiting season. He reportedly received $500,000 in NIL payments through the Arkansas program for a one-year deal, but, ultimately, he was unhappy, too. He is leaving early and will now be transferring to UCLA to join his brother, with about half of his one-year deal unfinished. See the media report here. Both Tennessee and Arkansas are reportedly considering legal action based on breach of the NIL contracts.

Some legal lessons

The sagas of the Iamaleava brothers highlight some legal lessons for college athletes and NIL deals. First, the money is real, and the schools are willing to pay and willing to negotiate. It is reported — but also denied — that Nico’s representatives wanted an increase in NIL payments to $4 million. If those sorts of numbers are being discussed, then, likely, at least a few top-tier athletes are getting those kinds of payments.

Second, off-season re-negotiations are happening, even if there are few media reports about it. This is just part of the new college football system.

Third, the NIL contracts are also real. Athletes signing NIL contracts should be fully aware of what is included. The Madden Iamaleava NIL contract reportedly contains a provision for a return of NIL monies if the athlete does not complete the full contract. Reports indicate that Arkansas believes it is entitled to a return of $200,000 or so of the $500,000 paid. As some are reportedly saying, “suing college athletes is a bad look,” but for this kind of money, lawsuits will eventually be filed. Likely, matters will be settled to avoid too much bad publicity. Also, likely, schools and conferences will get involved, and unofficial rules will be put in place to handle situations like this. In other words, UCLA might agree to handle the “money problem.”

Fourth, college athletes and their representatives are going to need experienced and talented legal assistance with these NIL contracts.

Fifth, school and conference rules are important now and will become even more important in the future. For example, the SEC Conference does not allow an athlete to pay immediately if there is a within-conference transfer. Thus, neither of the Iamaleava brothers could have played this year if they had gone to an SEC school. Thus, none of the SEC schools were “in the running” for the services of either of the Iamaleava brothers. This has been a long-time SEC rule, so it is probably not subject to legal challenge.

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What NIL Contracts Must Address: Lessons From High-Stakes Transfers

The Iamaleava sagas are not isolated events. They are the leading edge of a wave of NIL contract disputes that will define college sports law for the next decade. The underlying legal issues — breach, repayment obligations, transfer restrictions, and conference eligibility rules — are present in virtually every major NIL deal. Athletes, agents, and schools all benefit from understanding how these contracts work and where they fail.

NIL Contracts Are Legally Enforceable

The most important thing college athletes need to understand is that an NIL contract is a real contract. It is governed by the same principles of contract law that apply to any commercial agreement. Offer, acceptance, consideration, and mutuality of obligation are all present. When an athlete signs an NIL agreement with a school’s collective or a direct sponsor, they are accepting legally binding obligations. Breach of those obligations exposes the athlete — and potentially their family members or representatives who signed as guarantors — to civil liability.

The reported Arkansas position in the Madden Iamaleava matter — that he owes back approximately $200,000 for leaving with half a season unfinished — is a straightforward breach-of-contract claim. Whether Arkansas ultimately sues or settles, the legal theory is sound. Courts in most jurisdictions will enforce NIL repayment clauses provided they are drafted clearly and the repayment amount is proportional to the unperformed obligations.

Repayment and Clawback Clauses

NIL contracts frequently contain repayment provisions, variously called clawback clauses, repayment provisions, or liquidated damages clauses. These provisions specify what happens when an athlete does not fulfill the full term of the agreement. A well-drafted clawback clause should clearly state: (1) under what circumstances repayment is triggered (voluntary transfer, academic ineligibility, dismissal from the team, etc.); (2) how the repayment amount is calculated (pro-rata refund, a fixed sum, or a penalty); and (3) who is responsible for payment (the athlete alone, a parent guarantor, or a trust).

Athletes and their advisors often focus on the upfront payment amount and overlook the clawback provisions. This is a serious mistake. A $500,000 deal with a 50% clawback clause is effectively a $250,000 deal if the athlete transfers mid-season. Legal counsel reviewing the contract before signing can identify these provisions and negotiate their scope — or at least ensure the athlete understands the financial consequence of leaving early.

Conference Transfer Restrictions and Eligibility Rules

As the Iamaleava saga illustrates, conference rules operate independently of NIL contract terms and can significantly restrict an athlete’s options. The SEC’s within-conference transfer restriction — barring immediate eligibility for athletes who transfer between SEC schools — is a binding rule that was not invented for the Iamaleava situation. It pre-existed the NIL era and reflects the conference’s interest in competitive balance.

Athletes must treat conference rules as a threshold constraint before any NIL negotiation begins. An NIL deal with an SEC school that looks attractive financially is worth nothing if a transfer restriction means the athlete cannot play. The legal enforceability of these conference rules has been tested in courts following the Supreme Court’s 2021 decision in NCAA v. Alston, 594 U.S. 69 (2021), which held that NCAA compensation restrictions violate antitrust law when they go beyond genuinely education-related benefits. The boundaries of that ruling are still being worked out in lower courts, and athletes who believe a conference restriction is being applied improperly have potential legal recourse.

The Role of Legal Representation in NIL Deals

Most state NIL statutes now expressly permit student-athletes to hire agents, advisors, and attorneys to help negotiate NIL agreements. This was not always the case. Many early state NIL laws were silent on agent representation, which created a gap that inexperienced athletes fell into. Today, the legal framework is clearer, and athletes at every level — from five-star football recruits to mid-major basketball players — should have counsel before they sign.

An experienced NIL attorney does more than review contract language. They advise on the tax implications of NIL income (which is reportable as ordinary income and subject to self-employment tax), the interaction between the NIL agreement and the athlete’s eligibility status, and the athlete’s rights if the school’s collective fails to pay. They also help structure the athlete’s NIL activities as a business — registering trademarks in the athlete’s name, forming an LLC where appropriate, and ensuring the athlete’s brand is protected from unauthorized use. The stakes in today’s NIL market are too high to navigate without professional guidance.

The NIL attorneys at Revision Legal work with college athletes, high school prospects, families, and NIL collectives. If you are navigating an NIL deal — whether it is a new agreement, a renegotiation, or a transfer dispute — contact Revision Legal before you make any decisions.