Ultimately, the NCAA has created a disciplinary apparatus that imposes severe punishment on schools who defy its eligibility recommendations, while simultaneously escaping accountability for those recommendations by making the universities take the final action. This is a perversion of our constitutional system that purports to protect an individual’s ability to hold powerful actors accountable and instead renders athletes powerless. Schools escape accountability by deferring to the NCAA, while the NCAA claims its conduct is private and exempt from the requirements of constitutional rights.