## Facts

- Zion Williamson, then a Duke University basketball player, signed a written agreement granting Prime Sports Marketing, LLC and its president, Gina Ford, exclusive authority to represent him for marketing and professional sports opportunities.
- At signing, Williamson was enrolled at Duke, competing in intercollegiate athletics, and had not been declared permanently ineligible by any collegiate governing body.
- North Carolina’s Uniform Athlete Agents Act (UAAA) required athlete-agent registration before contracting with a student-athlete and required the contract to include specified, conspicuous warnings about potential loss of eligibility.
- Ford/Prime were not registered as athlete agents in North Carolina, and the agreement lacked the required warning language.
- Williamson terminated the agreement and sought declaratory relief that it was void under the UAAA; defendants argued the UAAA did not apply because Williamson allegedly had already engaged in conduct that would have made him permanently ineligible under NCAA rules.

## Issues

1. Whether Williamson qualified as a “student-athlete” under the North Carolina UAAA when the agreement was executed.
2. Whether noncompliance with the UAAA’s registration and warning-language requirements rendered the agreement void as a matter of law on the pleadings.
3. Whether post-judgment relief and leave to amend were warranted based on alleged legal error or additional allegations about Williamson’s purported ineligibility.

## Decision

- The court granted Williamson’s Rule 12(c) motion for partial judgment on the pleadings.
- The court held Williamson was a “student-athlete” under the UAAA at the time of contracting because he was participating in intercollegiate athletics and had not been declared permanently ineligible.
- The court declared the agreement void and unenforceable because Ford was unregistered in North Carolina and the agreement omitted the UAAA’s required warnings.
- In a later order, the court denied defendants’ motions to alter/amend or vacate and denied leave to amend, finding no clear legal error and concluding amendment would be futile.

## Legal Principles

- Under the North Carolina UAAA, a person participating in intercollegiate athletics who has not been declared permanently ineligible qualifies as a “student-athlete” for purposes of the Act.
- Conclusory allegations that a student-athlete would have been permanently ineligible under NCAA rules, absent an actual declaration of permanent ineligibility, do not remove the athlete from the UAAA’s coverage at the pleading stage.
- An athlete-agent contract covered by the UAAA is void if the agent is not properly registered in North Carolina and the contract lacks the statutorily required warning language.
- Post-judgment relief requires more than reargument; leave to amend may be denied as futile where proposed allegations would not change the statutory analysis or plausibly establish a dispositive fact.

## Conclusion

The court applied the North Carolina UAAA’s text to hold that Williamson was a protected student-athlete when he signed the agency agreement, and it declared the agreement void because the agent was unregistered and the contract omitted mandatory eligibility warnings; it later refused to reopen the ruling or allow amendments that would not alter that result.


Williamson v. Prime Sports Mktg., LLC, No. 1:19-cv-00593, 2021 WL 201255 (M.D.N.C. Jan. 20, 2021)