Junior Tuihalamaka was granted a Temporary Restraining Order on Wednesday that lets him return for a fifth year and enter the Transfer Portal. For a former Notre Dame linebacker, that is not a small procedural step. It changes what he can do next.
The ruling matters because Tuihalamaka has not signed with an NFL team, and the signed order in Louisiana says that point still sits at the center of the case. The order covers 16 players and gives them a path back into college football while they keep fighting for more eligibility.
That fight is part of a broader wave of lawsuits seeking extra seasons in college sports. Last month, a preliminary class-wide injunction in the U.S. District Court of Colorado gave the class of 2022 recruits a different kind of relief: those who used up their fourth season this spring were allowed to play a fifth season in 2026-27. But that Colorado ruling did not let players enter the portal, which is where the Louisiana order goes further.
The gap matters because the two orders do not do the same job. One addresses future playing time; the other also opens the door to movement. That difference is why a player like Tuihalamaka can be cleared to return and still leave room to change schools, even as the broader legal fight over college eligibility keeps running through the courts.
There is also one rule line the players do not all see the same way. It is generally accepted that once a player declares for the NFL and signs a contract, his college days are over, but several players in the Temporary Restraining Order say they do not agree that is the rule. Tuihalamaka is part of that dispute, and the fact that he has not signed with an NFL team keeps him inside the argument.
That leaves Notre Dame with a real roster decision if it wants him back. Marcus Freeman and his program would not be breaking one of the few rules everyone can agree on, but whether the school welcomes its former linebacker back is still the unanswered piece that will decide whether Wednesday’s order turns into an actual return.
