Clemson wide receiver Tristan Smith received a temporary injunction against the NCAA from a South Carolina judge Friday, clearing the way for him to play this season.
Smith had sued the NCAA in January after the organization denied his waiver for a fifth season of eligibility, arguing the decision was “a hallmark of capricious and arbitrary treatment” based on similar waivers that were granted to former junior college players like himself.
In her ruling, Judge Jessica A. Salvini of South Carolina’s 13th Judicial Circuit pointed to eligibility cases involving Malik Benson and Diego Pavia, former junior college players who were granted waivers for an additional year. Salvini said Benson’s case is “nearly identical to the present case.”
“The only material distinction the Court can identify between Mr. Benson’s case, and the instant matter is that Mr. Smith’s final Division I season falls in 2025-26 rather than 2024-25,” Salvini wrote.
Indeed, former junior college players in the graduating class of 2024-25 received a blanket extra year of eligibility after Pavia won his lawsuit. But that was not extended to players in the class of 2025-26, which includes Smith.
Smith wrote a message on X to “say thank-you to everyone that has been by my side through this whole process.”
— Tristan Smith (@DbkTristan) June 12, 2026
Attorney Darren Heitner, who represents Smith, called the ruling a “big win for our client” on X.
“The NCAA’s arbitrary application of its Five-Year Rule didn’t hold up,” Heitner wrote.
Smith played two years in junior college before transferring to FCS school Southeast Missouri State in 2024 and to Clemson in 2025. He started four games last season, catching 24 passes for 239 yards and a touchdown.
