Duke’s Darian Mensah can enter transfer portal but can’t play elsewhere, judge’s order says
By Matt Baker, Sam Khan Jr. and Stewart Mandel
Duke standout quarterback Darian Mensah can enter the transfer portal but cannot enroll at another school or play football for another program, according to a temporary restraining order granted by a North Carolina judge.
The written order, issued Wednesday, comes a day after Duke filed a lawsuit against Mensah in Durham County, N.C. in an attempt to prevent the second-team all-ACC pick from entering the portal. The judge, Michael O’Foghludha, temporarily granted most of Duke’s requests, preventing Mensah from joining another program or licensing his NIL somewhere else, at least through the next hearing, currently scheduled for Feb. 2. Duke has filed a demand for arbitration, and O’Foghludha wrote the temporary restraining order was “necessary for the protection of Duke University’s rights” in that process.
The judge’s order did not prevent Duke from entering Mensah into the transfer portal, which is expected to happen Wednesday. Mensah notified the school in writing of his intention to transfer Friday afternoon, hours before the sport’s lone transfer window was set to close. NCAA bylaws state that, once an athlete informs the school of their intention to transfer and follows the necessary procedures, the school has two business days to enter the player’s name into the portal. Because of Monday’s Martin Luther King Jr. holiday, Duke had until Wednesday to enter Mensah’s name.
Mensah is one of the top returning quarterbacks in college football going into the 2026 season and is the No. 1 player in The Athletic’s transfer quarterback rankings. Entry into the portal would allow schools to officially contact Mensah. Miami is considered the favorite to land him.
Duke is also expected to host San Jose State transfer quarterback Walker Eget, who entered the portal on Jan. 9, on a visit. Eget was a two-year starter for the Spartans.
In its lawsuit, Duke cited a two-year contract that Mensah signed in December 2024, which granted exclusive name, image and likeness rights to Duke through Dec. 31, 2026. The deal, which began as a third-party NIL agreement, transitioned to a revenue-sharing contract with Duke last summer under the terms of a multi-billion-dollar antitrust settlement known as the House settlement. As of July 1, 2025, colleges were allowed to distribute up to $20.5 million in revenue sharing directly to athletes across all sports for the 2025-26 school year.
The suit claims that if Mensah is allowed to break the contract by entering the transfer portal, enrolling at another school, playing football and/or licensing his NIL rights to another school, it would cause Duke “irreparable harm.” Mensah’s contract does not include an early termination, or “buyout”, clause.
The complaint also argues there is a “strong public interest” in this case and that allowing Mensah to breach the contract would “undermine the integrity of these agreements.”
“Mr. Mensah has an existing contract with Duke, which the university intends to honor, and we expect he will do the same,” a Duke athletics spokesperson said in a statement Wednesday. “The court-ordered temporary restraining order (TRO) issued yesterday ensures he does not violate his contract. The university is committed to supporting all our student-athletes, while expecting each of them to abide by their contractual obligations.”
O’Foghludha ordered Duke to post a $1,000 bond, which would go to Mensah if his side ultimately prevails. Quarterbacks of his caliber typically command millions of dollars in the NIL market.
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