Fifth-Place Swimmer Riley Gaines’ Lawsuit Against NCAA Dismissed By Federal Judge

A federal judge has dismissed a Title IX lawsuit filed by former collegiate swimmer Riley Gaines and other female athletes against the National Collegiate Athletic Association (NCAA), ruling that the plaintiffs failed to establish that the NCAA received federal financial assistance.

U.S. District Judge Tiffany R. Johnson of the Northern District of Georgia ruled that the NCAA is not subject to Title IX because the organization was not shown to be a recipient of federal funds. In her ruling, Johnson wrote, “There is no evidence that the NCAA ever received, or could have received, federal funds. Thus, Plaintiffs’ Title IX claims cannot proceed.”

Title IX generally applies to educational programs or activities that receive federal financial assistance. The question of whether the NCAA met that threshold became central to the lawsuit.

Gaines and the other plaintiffs argued that the NCAA received federal financial assistance through its involvement with the Concussion Assessment, Research and Education (CARE) Consortium, a research initiative involving the NCAA, the University of Indiana and the U.S. Department of Defense.

Johnson rejected that argument, finding that the federal funding went to the university and other research participants rather than to the NCAA itself. The court also rejected arguments that the NCAA could be considered a recipient of federal assistance indirectly through its member institutions or other arrangements.

The lawsuit, filed in March 2024, challenged NCAA policies that allowed transgender women to compete in women’s collegiate sports. The case centered in part on the 2022 NCAA Division I Women’s Swimming and Diving Championships, where Gaines, then swimming for the University of Kentucky, tied transgender swimmer Lia Thomas for fifth place in the 200-yard freestyle final. Thomas won the 500-yard freestyle at those championships, becoming the first openly transgender athlete to win an NCAA Division I championship.

The ruling did not determine whether the NCAA’s former transgender-athlete policies violated Title IX. Instead, the court concluded that the plaintiffs could not bring their Title IX claims against the NCAA because they had not established that the organization received federal financial assistance.

Following the ruling, Gaines said on Twitter (X) that her legal team plans to appeal. The plaintiffs have 30 days to file a notice of appeal with the U.S. Court of Appeals for the Eleventh Circuit.

The NCAA has since changed its transgender-athlete eligibility policy. In February 2025, the organization adopted a policy restricting athletes assigned male at birth from competing on NCAA women’s teams, following an executive order from President Donald Trump.