Court Makes Final Verdict on Clemson WR Tristan Smith's Eligibility

After being denied a fifth year of eligibility in November 2025 and subsequently suing the NCAA in January, Clemson wide receiver Tristan Smith's case has finally reached a conclusion.

Clemson wide receiver Tristan Smith has finally been granted a fifth year of eligibility after fighting against the NCAA for months. | Bob Donnan-Imagn Images

On Friday morning, Clemson Tigers wide receiver Tristan Smith received a temporary injunction against the NCAA from Judge Jessica A. Salvini of South Carolina's 13th Judicial Circuit, making him eligible to play his fifth year in 2026-27.

Following the ruling, the former junior college (JUCO) standout took to Instagram to make a post that was captioned, "The Marathon continues. I'm back."

This entire situation started over six months ago, in November, when the NCAA denied Smith's individual waiver to play an extra year.

The denial led the senior to hire sports lawyer Darren Heitner and his team as representatives on January 3, consequently beginning a lawsuit against the NCAA on January 21, with lawyer Alan Wilmot later stating, "The crux of our case is simply the arbitrary application of this waiver and why [Smith] is not being afforded the same relief as other individual athletes have been afforded in the past."

What Wilmot is pointing to by saying this is that last year, the Division I Board of Directors approved a waiver, which was prompted by a lawsuit from former Vanderbilt quarterback and Heisman finalist Diego Pavia, that excludes a season of JUCO experience from a player's eligibility clock. 

It worked for Pavia, former Oregon Duck Malik Benson — who was also represented by Heitner while trying to fight for an extra year — and just about every other player looking for an additional year during the 2024-25 season. However, it was not granted to players who graduated in 2025-26, like Smith.

"A year ago, we came close to taking legal action against the NCAA to secure an additional year of eligibility for Malik Benson," Heitner said in January. "Now, Benson is battling for a spot in the national championship with Oregon following an outstanding season."

Initially, Smith filed a request for a temporary restraining order against the NCAA, which Salvini later denied. But, like Smith's legal team, she criticized the way the NCAA had handled the case.

"The NCAA's denial appears arbitrary and capricious, consistent with judicial findings in other districts," Salvini said. "This order is necessary because of the immediate need to allow Mr. Smith to join his team for practices and roster planning, to prevent irreparable harm to his college and professional football career, and to allow him to effectuate his NIL and revenue-sharing opportunities."

This rejection ultimately caused Smith and his team to file for a temporary injunction. The hearing, originally tentatively set for February 3, was first postponed to March 31, then to June 8.

During the months of waiting, Smith found reason for optimism in similar cases: a March injunction had cleared the way for Ole Miss quarterback Trinidad Chambliss to retain his 2026 eligibility, and more recently, former Indiana and Cincinnati quarterback (now at Texas Tech) Brendan Sorsby was granted eligibility by a judge on Monday after being ruled ineligible by the NCAA over sports betting issues, including betting on the Hoosiers frequently back in 2022 when he was still apart of the team.

Both rulings sparked controversy, but the Sorsby case drew far more backlash, with most observers feeling it was, to put it nicely, ridiculous.

That leads us to this past Monday, when Smith finally got his day in court. However, there was no ruling that morning, as Salvini said she would have her decision "by the end of the week." It took her just four days to reach a conclusion, and, as mentioned, it ended up being in Smith's favor.

While the talented wideout has gone through a sea of trials and tribulations over the past several months, even suffering an injury in spring practice amidst all the controversy, he will now officially be back in Death Valley for another season.

Brief Career Timeline

• Hutchinson Community College (2022-23): 7 games played, 2 receptions for 91 yards and one touchdown.

• Hutchinson Community College (2023-24): 10 games played, 14 receptions for 140 yards and one touchdown.

• Southeast Missouri State (2024-25): 12 games played, 76 receptions for 934 yards and six touchdowns.

• Clemson (2025-26): 13 games played, 24 receptions for 239 yards and one touchdown.