The NCAA’s authority has taken a significant hit as the battle over eligibility rules between the organization and student-athletes has spilled into the courtroom. Clemson wide receiver Tristan Smith is the latest athlete to bypass the NCAA and fight for a fifth year of eligibility in a South Carolina courtroom. On Friday, Pickens County Circuit Court Judge Jessica Salvini handed Smith a temporary victory by granting a preliminary injunction. While the ruling allows Smith to play during the 2026 season, his case could set a precedent for Temple’s Khalil Poteat, who is engaged in a similar legal battle.

The 22-year-old WR had filed a lawsuit against the NCAA in January after it had denied his waiver request for a fifth year of eligibility late last year. After two years at Hutchinson Community College, Smith came to Clemson from Southeast Missouri State ahead of the 2025 season and recorded 24 catches for 239 yards and a touchdown the previous season. If he were not eligible to play this season, he’d have to enter the NFL supplemental draft by the league’s June 22 deadline.

Judge Jessica Salvini wrote in her ruling:

“The NCAA is restrained and enjoined from enforcing, applying, or attempting to enforce the November 14, 2025, denial of Mr. Smith’s waiver declaring him ineligible to compete in the 2026-2027 football season of competition at Clemson University,” and stated that,  “… The NCAA shall declare Mr. Smith immediately eligible for competition during the 2026 – 2027 season.”

With this injunction, Smith successfully bypasses the NCAA’s restrictions and mandates that would’ve caused what the court deemed “irreparable harm” to his immediate collegiate and long-term professional career.

Judge Salvini heavily cited a massive legal precedent set earlier in the week on June 8, 2026, when a Lubbock County Court in Texas granted a similar injunction to Texas Tech quarterback Brendan Sorsby. Salvini noted that, much like the Sorsby case, depriving a player of team activities, coaching staff instruction, trainer access, and the ability to make an informed professional draft decision can damage the young athlete for life.

Prominently, she declared that sports governing bodies cannot legally enforce these decisions while lawsuits sit pending.

It opens the legal floodgates for similar cases in the Football Bowl Subdivision (FBS) landscape. Khalil Poteat is mounting his own lawsuit against the NCAA, as Smith got this win based on a different precedent.

NCAA’s precedents set the stage for legal fight by student-athletes

Just hours after the decision on Tristan Smith, Temple defensive lineman Khalil Poteat announced through his representative, Ed Waz, that he remains in the transfer portal and is preparing to file an identical lawsuit against the NCAA for a final season of eligibility. Poteat’s situation mirrors the same JUCO to FBS pattern as Smith’s. Players taking the legal route underscores the growing pushback by the young athletic community against the NCAA’s current eligibility rules.

The core of Smith’s legal argument, which will be the foundation for Poteat’s upcoming challenge, is based on how the NCAA calculates historical playing time for athletes transitioning from the JUCO level. Smith’s attorney, Darren Heitner, publicly called out the governing body’s logic by pointing to a previous incident.

“The NCAA gave everyone in Diego Pavia’s class an extra year, not counting 1 year of JUCO,” Heitner previously said on X. “To not give all former JUCO players an extra year of eligibility would be arbitrary and capricious.”

Heitner argued that failing to extend that same courtesy to all former junior college athletes constitutes unequal treatment.

With Temple’s Poteat now weaponizing the same legal strategy, the NCAA faces a massive wave of litigation that could permanently reshape its management of former JUCO athletes.