Judge makes decision on Clemson receiver’s eligibility status. Here’s the ruling
Tristan Smith is back.
On Friday, a local judge granted the Clemson wide receiver’s request for a temporary injunction against the NCAA and cleared the way for Smith to suit up for the Tigers football team in 2026 after a six-month court battle over his eligibility.
Smith sued the NCAA in January, arguing that the organization was unfairly counting his two seasons at a non-NCAA junior college against his NCAA eligibility. The NCAA had maintained Smith was out of eligibility following the 2025 season.
But South Carolina circuit court judge Jessica Ann Salvini granted Smith’s request for a temporary injunction (also known as a judicial “stay”) against the NCAA.
“The NCAA shall declare Mr. Smith immediately eligible for competition during the 2026-2027 season,” Salvini wrote in a five-page ruling released Friday.
One of Smith’s lawyers, Darren Heitner, also confirmed in a post on X that his client will be able to play in 2026 and called the ruling a “big win” for Smith.
“Justice for Tristan!” Heitner wrote.
In simplest terms, Friday’s injunction bars the NCAA from enforcing its eligibility rules on Smith pending the outcome of his lawsuit. It also allows the 6-foot-5 receiver to play a fifth and final year of college football at Clemson.
Smith’s case was heard in South Carolina’s 13th Judicial Circuit, which covers Greenville County and Pickens County (where Clemson’s campus is located). Salvini, the judge assigned to the case, does not hold any degrees from Clemson.
Why Clemson’s Smith won injunction vs. NCAA
The NCAA denied Clemson’s waiver request to award Smith a fifth year of eligibility in November because he’d played four total seasons of college football without a redshirt, although only two came at the Division I level.
Smith played the 2022 and 2023 seasons at Hutchinson Community College in Kansas before transferring to FCS Southeast Missouri State in 2024 and Clemson in 2025.
Former JUCO athletes in the graduating class before Smith (2024-25) received a blanket extra year of eligibility under the “Pavia rule,” triggered by a lawsuit from former Vanderbilt star quarterback Diego Pavia.
But the NCAA didn’t extend that waiver to junior college athletes in the following class (2025-26), which included Smith. His lawyers had argued that the NCAA extending a waiver to one JUCO class vs. every JUCO class was an “arbitrary application” of its rules harming Smith’s career chances.
This specific argument resonated with Salvini. In her ruling, she cited the case of Malik Benson, one of Smith’s former Hutchinson Community College teammates. After playing two seasons at the JUCO in 2021-22, Benson played three additional seasons at Alabama (2023), Florida State (2024) and Oregon (2025).
The NCAA granted Benson an eligibility waiver for the 2025 season. After a career year with Oregon, he was a sixth-round draft pick of the NFL’s Raiders in April.
“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.
Salvini also wrote that missing the 2026 season would constitute “irreparable harm” for Smith because it’s a “time-limited opportunity,” citing similar eligibility rulings across the country (including one for Texas Tech quarterback Brendan Sorsby).
“If Mr. Smith is prohibited from participating in the upcoming football season at Clemson University, Mr. Smith would lose personal development, experience, and professional prospects,” she wrote.
How Tristan Smith fits in at Clemson in 2026
Smith, a 6-foot-5 receiver from Georgia, became a fan favorite during his lone year with the Tigers and flashed his potential with 24 catches for 239 yards and a touchdown in 13 games (four starts).
Clemson had reserved a spot on its roster for Smith if he became eligible. He was allowed to participate in all team activities as he awaited a legal outcome.
Clemson coach Dabo Swinney also said in February that if Smith didn’t win his injunction, he could stay on with the team as a student coach and finish his degree through the athletic department’s Tiger Trust program for former athletes.
The Tigers have star power at wide receiver in rising juniors Bryant Wesco Jr. and T.J. Moore, both of whom are potential 2027 NFL Draft picks. But Smith is a significant addition for Clemson’s receiver depth and likely slides in as a top five option with Wesco, Moore, Tyler Brown and Cole Turner.
This story was originally published June 12, 2026 at 12:01 PM.
