Nevada baseball player Noah Blythe has filed an emergency motion asking the U.S. District Court for the District of Nevada to stop the NCAA from enforcing the organization’s five-year eligibility rule against him.
Blythe is attempting to play this season for the Wolf Pack, which opens its campaign Friday at Ole Miss. But the NCAA has denied Blythe’s eligibility request to play in 2026 despite the fact he has never played at the Division I level.
A native of Santa Clarita, Calif., Blythe began his college career in the 2021 season at Hawaii Pacific before a three-year stint at Antelope Valley and a return to Hawaii Pacific last season. His college journey includes the following:
2021 season: Hawaii Pacific (partial season due to COVID-19)
2022 season: Antelope Valley (full season)
2023 season: Antelope Valley (partial season, broken hand)
2024 season: Antelope Valley (school shut down midyear)
2025 season: Hawaii Pacific (full season)
During Blythe’s five college seasons, only two were full years, with the 2021 campaign impacted by COVID, the 2023 season cut short by injury and the 2024 season ending after 15 games when Antelope Valley cease all operations due to severe financial constraints after an emergency order from the California Bureau for Private Postsecondary Education.
Antelope Valley was an NAIA school outside of the NCAA’s jurisdiction while Hawaii Pacific is an NCAA Division II school, giving him only two seasons, and one full year, in the NCAA. Representing Blythe is Reno-based lawyers Steven A. Caloiaro and Mackenzie E. Robinson of Dickinson Wright PLLC. The NCAA allows athletes to play four seasons over a five-year period, although it routinely grants exemptions. Blythe’s waiver request was denied.
“The NCAA should not be permitted to punish Noah by denying him eligibility to play NCAA DI baseball this season simply because he chose to spent part of his college baseball career outside of the NCAA,” Caloiaro wrote in an email to NSN.
A hearing has been set for Friday, which could allow Blythe to join the Wolf Pack. Blythe has not been able to practice with Nevada and is not currently listed on the team’s online roster. But he is enrolled in classes at the university.
In July, former Nevada football player Cortez Braham Jr. got an injunction for a seventh season of college eligibility, including his fourth in the NCAA, by Miranda Du of the U.S. District Court for the District of Nevada. Braham spent that at Memphis. The NCAA allowed all junior-college and NAIA athletes an extra year of eligibility in 2025-26 if they were within their five-year clock following a lawsuit from Vanderbilt quarterback Diego Pavia. Blythe is asking for a sixth year of eligibility, although it would be only his third at an NCAA member.
A 6-foot-3, 220-pound outfielder, Blythe hit .443 with a .788 slugging percentage last season for Hawaii Pacific. He smashed 15 homers, 24 doubles and drove in 76 runs en route to PacWest Player of the Year honors. He also was named the Region Player of the Year after leading the Division II ranks in average and hits. Blythe was a 2025 MLB draft hopeful but went unselected before committing to Nevada.
“Noah was invited to play with the University of Nevada, Reno’s baseball team in the 2026 season,” Caloiaro wrote in an email to NSN. “Their first game is this Friday, February 13, against Ole Miss. This game is supposed to be Noah’s NCAA DI baseball debut, but the Five-Year Rule renders him ineligible to play. The Five-Year Rule is the combination of three NCAA bylaws, which, together, say that a college athlete has five years of eligibility to play four seasons. However, that five-year clock starts to run the second the college athlete enrolls in a full-time course load, regardless of whether they are students at a junior college, an NAIA institution or an NCAA member school. Noah applied for a waiver of the five-year rule, but was informally denied, and no formal written decision was instituted to which he could appeal.
“For students that start their college athletic careers outside of the NCAA, the five-year clock prevents them from playing four full seasons at an NCAA member school. For Noah specifically, this means his five-year clock started to run his first semester at Hawaii Pacific. It included the partial season he played during COVID, the partial season he played before he broke his hand and the partial season he played before his school literally went out of business. Even though Noah has only played two seasons of baseball at an NCAA member school (and one of those seasons was a partial season), the NCAA Five-Year Rule forbids him from playing this season with the University of Nevada.
“In doing so, it unfairly and arbitrarily denies him all of the opportunities that come with playing DI baseball. These opportunities include the chance for Name, Image, and Likeness (NIL) deals, the exposure necessary to rocket his baseball career to a professional league, national television and radio airtime, high-quality coaching and training, contests against elite opponents and the unmatched scholastic and academic opportunities offered by a school of the University of Nevada’s caliber.”