A federal magistrate judge has dismissed a lawsuit challenging the California Interscholastic Federation's transfer and name, image and likeness rules for the second time, leaving former prep football and track athlete Dominik Calhoun with until September 10 to file an amended complaint or take his fight to the Ninth Circuit. The ruling also means CIF's internal discussions on possible transfer policy changes, paused while the case played out, may now resume.
U.S. Magistrate Judge Laurel Beeler granted CIF's motion to dismiss the case for a second time, according to Los Angeles Times reporter Eric Sondheimer, who covers the case out of Northern California federal court. Calhoun, a former high school football player who is now a safety at Boise State University, first filed the class-action suit in May 2025 in the U.S. District Court for the Northern District of California, alleging that CIF's transfer and athlete compensation rules violate federal antitrust laws, according to Sports Illustrated.
Before landing at Boise State, Calhoun competed in football and track at El Cerrito High School from 2021 to 2022 and at Pittsburg High School from 2023 to 2024, according to Legal Newsline. Those school changes are directly tied to his challenge of CIF's transfer penalties, which fall under CIF Bylaw 207. That bylaw requires student-athletes who switch high schools without a genuine, family residential move to sit out a period, or face up to a full year of varsity ineligibility, in sports they previously played, unless a hardship waiver is granted, per California Sports Law.
A Complicated Legal History
This is not the first time the case has stumbled in court. In a ruling issued in January, Judge Beeler rejected CIF's defense of 11th Amendment sovereign immunity, holding that the federation is a private voluntary association rather than a government entity, a finding reported by Courthouse News. That distinction mattered because sovereign immunity would have shielded CIF entirely from federal antitrust litigation.
Yet the same January ruling was not a clean win for Calhoun. Judge Beeler upheld CIF's transfer restrictions under state-action antitrust immunity while allowing antitrust claims to proceed regarding CIF's prohibition on student-athletes earning NIL income while wearing school uniforms or logos, according to the same Courthouse News report. The court also dismissed all claims against the corporate media co-defendants named in the suit, finding that merely entering commercial broadcast contracts with CIF did not establish an unlawful antitrust conspiracy.
Those media co-defendants had included some of the biggest names in prep sports broadcasting: PlayOn! Sports, owner of MaxPreps, GoFan and NFHS Network, along with Playfly, SBLive Sports and Spectrum SportsNet, per Legal Newsline's reporting. Their exclusive rights to stream and monetize California high school events had made them targets in the original filing, but the court found no evidence they set or enforced CIF's eligibility rules themselves.
New Plaintiff Joins as Case Widens
As the litigation dragged on, the case expanded to add Mater Dei High School junior football player Patrick Hall as a co-lead plaintiff alongside Calhoun, a move reported by California High School Athletes Law that reflected the need for an active current student-athlete to preserve standing in the suit since Calhoun had already graduated. Calhoun still challenges both CIF's transfer rules and its restrictions on name, image and likeness rights, though the transfer piece of his claim has repeatedly run into the state-action immunity wall in court.
CIF operates as a private, dues-funded nonprofit association that governs interscholastic athletics for roughly 1,600 public and private high schools organized into 10 regional sections statewide, according to Antitrust Advocate. That reach explains why a single lawsuit out of Northern California federal court carries implications for transfer and compensation rules affecting prep athletes across the state.
What Happens Next
CIF had paused consideration of possible transfer policy changes while the lawsuit played out, according to the Los Angeles Times report, with those internal reform discussions dating back to April 2025. Now that Judge Beeler has dismissed the case a second time, those conversations may resume, though nothing has been finalized.
Calhoun's options are narrow and time-limited. He may file an amended complaint by September 10, or he may choose instead to appeal the dismissal. Nationally, roughly 30 state high school athletic associations allowed student-athletes to earn NIL compensation in some form as of 2025, according to Sports Illustrated, a landscape that continues to fuel legal pressure on holdout states like California even as CIF's core transfer bylaws remain intact for now.
