With an infusion of behavioral economic theory and close scrutiny of existing NCAA-related antitrust case law, this Comment examines how the framing of the issue of whether college athletes should be paid has warped the legal analysis of the NCAA’s limit on athletics-based compensation. Moreover, it proposes that properly framing the student-athlete compensation dilemma exposes the
illegality of the NCAA’s current grant-in-aid apparatus for Division I athletes under section 1 of the Sherman Antitrust Act.

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