UPDATE: We’ve published a new analysis looking at the successful World Aquatics antitrust settlement as a potential roadmap for NCR and Justin Hale, following the court’s recent dismissals.
In a significant development in the ongoing legal disputes within US rugby, a federal court has dismissed National Collegiate Rugby’s (NCR) lawsuit against USA Rugby. The decision, handed down by the U.S. District Court for the Western District of Texas, is based on the court’s determination that the issues raised by NCR fall under the jurisdiction of the Ted Stevens Olympic and Amateur Sports Act, and should therefore be handled through the United States Olympic and Paralympic Committee (USOPC).
Why the Lawsuit Was Dismissed
According to Judge Robert Pitman’s decision on September 11, the court does not have the authority to hear these complaints. The Ted Stevens Act, which grants the USOPC and its national governing bodies (NGBs) like USA Rugby their authority, also provides a specific legal pathway for disputes. This path requires an organization to first file a formal complaint with the USOPC, which then holds a hearing and can refer the matter to arbitration.
Judge Pitman stated that the Ted Stevens Act preempts, or overrides, both the federal and state-law claims that NCR made, including allegations of tortious interference, defamation, and deceptive trade practices.
The judge’s decision to dismiss the case was made sua sponte, a Latin legal term meaning “of one’s own accord.” This means the court made the decision without USA Rugby having to file a specific motion for dismissal on those grounds.
Divergent Paths for the Plaintiffs
While the legal rationale for the dismissals is rooted in the Ted Stevens Act for all parties, the outcomes for the plaintiffs are not the same.
For Christopher Micheletti’s case, the court reached a conclusion that resulted in a final judgment and the dismissal of his lawsuit. He would have to start the legal process over if he chooses to pursue his federal claims.
For Justin Hale’s case, the outcome was notably different. The court did not dismiss it. Instead, the judge ordered Hale to file an amended complaint with only the federal claims. This is a key distinction, as it means Hale’s case is still active and moving forward without him having to start the entire process over.
The larger lawsuit from National Collegiate Rugby was also dismissed. The court ruled that this case, like the referee lawsuits, falls under the jurisdiction of the Ted Stevens Act. The dismissal was issued without prejudice, which is a crucial detail. This means the lawsuit is not dismissed forever, and NCR can still pursue its claims. However, it must follow the legal process outlined in the Ted Stevens Act, filing a written complaint with the USOPC for resolution.
The Path Forward
With this ruling, the legal focus shifts from the federal courts to the USOPC’s grievance procedures. The lawsuit is dismissed, but the underlying complaints remain. NCR (and the referees) now have a clear legal roadmap provided by the court: to file a written complaint with the USOPC and, if needed, proceed to arbitration.
The question now remains whether NCR or the referees will take this next step. The lawsuit was dismissed despite USA Rugby asking the court to stay the case and order it into arbitration, a request the court said it did not have the power to grant. It now falls to NCR to decide if they will engage with the process outlined by the Ted Stevens Act.
Ongoing Coverage
For a complete history of this story, please see our previous articles:
- Oct 16, 2025 “Dismissed, Not Defeated: The World Aquatics Case as Rugby’s Governance Blueprint“: This article compares the USA Rugby legal outcomes to the World Aquatics settlement, arguing that the court’s dismissal mandates a new, powerful strategy through the USOPC.
- Oct 6, 2025 “NCR Lawsuit Against USA Rugby Dismissed, Citing Ted Stevens Act“:The article details the federal court’s dismissal of the NCR and Micheletti lawsuits, ruling that the Ted Stevens Act requires the disputes be handled by the USOPC. It notes that Justin Hale’s case was not dismissed and remains active.
- Sep 2025 “Legal Battles Against USA Rugby See Key Developments“: The article reports on key developments in the legal battles against USA Rugby, noting that a motion to consolidate three separate lawsuits was denied.
- May 2025 “Governance on Trial: Hale and NCR Lawsuits Join Forces Against USA Rugby“: This article discussed the initial filings and the motion to consolidate the three lawsuits.
- March 2025 “Another Legal Challenge for USA Rugby: NCR Files Lawsuit Alleging Defamation, Fraud, and Interference“: This piece broke the news of the NCR lawsuit and detailed its specific allegations.
- December 2024 “Fractured Framework: What Justin Hale’s Lawsuit Reveals About U.S. Rugby’s Governance Challenges“: Our first report on the topic, this article outlined the claims made by Justin Hale and explored what his case revealed about the broader governance issues in American rugby.