Court of Petty Appeals: Morris, Chandler v. National Collegiate Athletic
Morris, Chandler
v.
National Collegiate Athletic Association (NCAA)
78 U. Va. 21 (2026)
Moore, J., delivers the opinion of the Court, in which Berklich and Wu, C.J.J., and Vanger, Lawson, Boatright, Lozada, and Koeppel, J.J. join.
Moore, J., delivers the opinion of the Court.
Given the reputation of the same Court as one of the foremost fora for figuring cases of the most modern and urgent sort, the plaintiff has seen fit to remove the foregoing case forthwith from our esteemed brethren of the Charlottesville Circuit Court. The case does indeed present a situation of first impression for the Court, as the field of collegiate athletics is one of the few fields changing as quickly as that of the recruitment of legal scholars of the same bench. This speaks nothing of the fields of Copeley and yonder Park, which have also seen frequent changes in recent weeks from rinks of ice to grassy expanses sans knolls or Chuck Nolls to covered in snow and mud and back to grass. In this instance, the plaintiff seeks a further year of eligibility from the National Collegiate Athletic Association to further his collegiate career with the University of Virginia’s football team.
Jurisdiction
The Court must first address whence the jurisdiction of the same is to be found. Typical methods seeking to onfindaþ jurisdiction in that repository of those items considered lost awaiting a finder in the librarium are sadly insufficient in the case of the search for jurisdiction; perhaps a repository such as is run by our Japanese counterparts would be more effective, but sadly this point is moot in the same way as many of our own courts are (one would think that the students of today mayhaps be better served by considering active issue of the day in the same way as the same Court instead of issues already settled and rendered moot, but at this point whether or not the same has jurisdiction to rectify this is still to be known). West, Mark D., Losers: Recovering Lost Property in Japan and the United States, 37 L. & Soc. Rev. 369 (2003).
Our initial search for jurisdiction having proved nearly as fruitless as those voyages that preceded Lind’s famous study, the Court then must confront what was sought to be avoided, that is, the Petty Rules of Civil Procedure, in the same way as the Fellowship was forced to pass through Khazad-dûm after their initial quest on Mount Caradhras was stymied. James Lind, A Treatise of the Scurvy, in three parts: Containing An inquiry into the Nature, Cauſes, and Cure, of that Diſeaſe: Together with a Critical and Chronological View of what has been publiſhed on the ſubject (1753); John Ronald Reuel Tolkien, Fellowship of the Ring (1954). A consultation of the aforementioned Petty Rules of Civil Procedure proves less costly than an activity of the same with the alumni of our fellow residents of the Grounds of the North and reveals jurisdiction to be found in Rule 9, which is blank to the point of not existing, thus making the Court the Rubén Cervantes of this case. F1 (Apple 2025). Just as our brother of yesteryear found a tabula rasa sufficient for all manner of conjecture, so too will the same Court. John Locke, An Essay Concerning Human Understanding (1690).
Issue (or Iſſue if the eſteemed Lind iſ conſidered an amicuſ curiae)
Having onfundon jurisdiction, the Court is left to redeploy its esteemed and wise intellectual heft to the question at hand, or at court rather, in much the same way as Ludendorff and von Hindenburg redeployed the German armies from the Eastern Front to the West for their spring offensives of 1918. See Jonathan Doe v. Benvin Lozada 78 U. Va 5 (2025); the dissent to Albino Squirrel v. UVA Football Fans 78 U. Va 7 (2025); numerous other cases of this and yesteryear; and James L. Stokesbury, A Short History of World War I 259 (1981). That question is whether the plaintiff is to be held to the NCAA regulations delimiting a student’s eligibility or whether there is to be found an exception to be accepted by the Court and by extension the NCAA.
Response
Both parties agree on the plaintiff’s status in all but one of the preceding football seasons, rendering the decision of the status in the 2022 football season the crux of the case, as opposed to the horcrux of the case, which would have rendered it a moot case of the type in which various colleagues of the court specialize. J.K. Rowling, Harry Potter and the Deathly Hallows (2007). In that fateful 2022 season, the plaintiff played parts of three games for the Texas Christian University Horned Frogs. The plaintiff claims that this season was a Maia Duvall-esque medical redshirt season, which would render him able to merit a waiver to the Five-Year Rule. John Scalzi, Redshirts (2013); 2025-26 NCAA Division I Manual § 12.6.1.7.1. The plaintiff further claims that the mental health of the same was so affected as to require treatment up to and including participating in games despite the physical injury. While unorthodox and vigorously contested by the defense, such treatment is well-established precedentially and accords with the rules of the NCAA. Smalley v. Baker, 262 Cal. App. 2d 824 (1968).
Remedy
Having found in favor of the plaintiff, two remedies are hereby ordered:
1. The plaintiff is to be allowed to play the 2026 season with the Virginia Cavaliers under the express condition that he lead the team to ultimate victory.
2. The principle that no one, not even a King or Queen, is above the law is well established. The Magna Carta of Edward 1 (1297), 25 Edw. 1. According to this and the Court’s commitment to the Bit, the Court finds that the NCAA ought to follow its own rules as a remedy in equity. Petty Rules of Civil Procedure § 3. Upon extrapolation of their rule that eligibility is limited to five years, notwithstanding extenuating circumstances of the like experienced by the plaintiff, the Court finds that the NCAA has been in operation since 1906, thus greatly exceeding the five-year limit. It is hereby disbanded after a long history of questionable decisions largely targeting prominent Midwestern basketball schools for no apparent reason. “It [won’t] be the same without you. [It’ll be] better.” See Roman Roy, Succession: Hunting.
Demitry, C.J. Emerita, dissenting.
I write separately for two reasons. The first is institutional. The second is ophthalmological.
To begin with the institutional matter, I must register my disappointment—indeed, my deep and abiding resentment—that the Court’s caption lists the joining members of the majority as “Berklich and Wu, C.J.J., and Vanger, Lawson, Boatright, Lozada, and Koeppel, J.J.” while somehow neglecting to note the continued existence of this Court’s Chief Justice Emerita. Titles, like eligibility waivers and the occasional iced-over Copeley field, may come and go with the seasons, but basic respect for the traditions of this Court should not be so casually redshirted. The failure to include the designation “C.J. Emerita” is therefore a grievous omission that I will not soon forget, though I will almost certainly bring it up again at every available opportunity.
But my more substantive objection concerns the opinion itself.
As a matter of longstanding judicial principle, I have maintained that any opinion which becomes too incomprehensible to read forfeits the presumption of correctness ordinarily afforded to the written work of my colleagues. This doctrine—sometimes referred to in chambers as the I Swear to God Andrew Your Obsession with the word “Onfindaþ” Is My 13th Reason Why rule—exists for a simple reason: courts are meant to resolve disputes, not to reenact the entire canon of Western literature while wandering through a procedural labyrinth.
The majority opinion before us, regrettably, fails this test.
The Court begins with a discussion of jurisdiction that involves: a Japanese lost-property repository, a medical treatise on scurvy from 1753, the Mines of Moria, a Formula One driver, John Locke, and what appears to be a brief but earnest attempt to summon the ghost of J.R.R. Tolkien. At some point in this intellectual relay race, the Petty Rules of Civil Procedure are mentioned, though not so much consulted as politely waved at while the Court continues sprinting toward further digressions.
By the time the opinion reaches the issue presented, the reader has been transported through eighteenth-century naval medicine, the Western Front of 1918, and the metaphysical status of horcruxes. While I applaud the majority’s admirable commitment to interdisciplinary scholarship, I question whether the eligibility of a college football player truly requires a jurisprudential tour through Middle-earth, World War I, and Hogwarts before halftime.
There exists, in short, a point at which cleverness becomes camouflage. The opinion has passed that point and continued several miles down the road.
Nor can I ignore the stylistic innovations on display. The Court periodically replaces ordinary spelling with what I can only assume is an enthusiastic reenactment of eighteenth-century typesetting—complete with long s’s and the occasional mysterious ligature. I respect historical authenticity as much as the next jurist, but I do not believe that the proper interpretation of NCAA eligibility rules requires us to write as though the printing press has just been invented.
Indeed, the opinion has what might best be described as the energy of what I call “weapons-grade homeschooling”—earnest, wide-ranging, impressive in its ambition, but fundamentally incapable of remaining on the assigned topic for more than three consecutive sentences.
This Court has always prided itself on clarity. Our finest opinions explain difficult questions in a way that allows the reader to follow the reasoning from premise to conclusion without needing a stack of literary references and a historical atlas. When an opinion instead reads like a bibliography that has become sentient and wandered into the U. Va. Reports, something has gone terribly wrong.
Accordingly, I dissent on principle.
Not because I am certain the majority’s conclusion is wrong—although it may very well be—but because I refuse to endorse an opinion that requires the reader to fight their way through the Mines of Moria merely to determine the eligibility status of a college quarterback.
If the Court wishes to grant the plaintiff another year of eligibility, it should say so plainly. If it wishes to deny it, it should say that plainly as well. What it should not do is compose a literary obstacle course that leaves the reader unsure whether they are adjudicating a football waiver or walking in on a drunk and syphilis-riddled table read of Finnegan’s Wake. And if anyone compares this opinion to any statement made by Judge Stephanos Bibas, respectfully meet me in the loading dock by the dumpsters behind the Law School tonight. The tornado is the least of your worries.
For these reasons—and also because the Court forgot my title—I dissent.