Duke sued quarterback Darian Mensah on Monday to try to enforce its contract against the outgoing star.

On Jan. 16, the last day for athletes to enter the transfer portal, Mensah announced his intention to leave Duke. The lawsuit states that Mensah would sign away rights he has already guaranteed to Duke—including his NIL “with respect to higher education and football”—if he enters into a contract with another school.

In its 44-page suit filed in Durham County Superior Court, Duke argues that Mensah’s transfer decision violates the contract he signed with the school through Dec. 31, 2026. The suit says that Mensah’s contract dictates all disputes must go through arbitration, a process the school has already initiated, and that if the quarterback leaves, Duke’s ability to seek relief through arbitration will be significantly limited. The filing also says Mensah, his family, or his representatives breached the contract by discussing his Duke deal or transferring with another school.

“Mensah’s actions violate numerous provisions of his contract with Duke University and disregard his promises and obligations to the University,” the suit says. “And, as Mensah agreed when he signed his contract, such breaches cause Duke irreparable harm for which there is no adequate remedy at law and, in the event of any such breach, Duke is entitled to injunctive or other equitable relief.”

Mensah had previously announced in December he would stay at Duke. The quarterback who started his career at Tulane led the Blue Devils to a 9–5 record and the ACC title this season.

Duke requested the judge issue a temporary restraining order to block the quarterback from entering the transfer portal while the arbitration process unfolds. Mensah’s attorney, college sports lawyer Darren Heitner, tells Front Office Sports that following a hearing earlier Tuesday, he anticipates the judge will formally deny Duke’s request. The judge is also a Duke basketball season-ticket holder and is recusing himself moving forward, Heitner says.

Mensah can’t play or enroll at another school until a new judge reviews the case, Heitner said in a post Tuesday afternoon.

Mensah has been linked to Miami, which fell Monday night at home to Indiana in the national championship game. Heitner, who teaches at Miami School of Law, tells FOS he can’t comment on those rumors.

Duke and Mensah are not the only messy case study of schools trying to enforce their contracts with athletes who wish to transfer in the new era of college football. Washington considered suing Demond Williams during a dramatic 48 hours earlier this month before the quarterback announced he would stay in Seattle.

Last summer, Wisconsin sued Miami for “tampering” when Xavier Lucas (who is also represented by Heitner) transferred after signing “binding” contracts with the school and its name, image, likeness collective. That case is still ongoing.

Beautiful snow-globe NFL playoff games, like the one played between the Bears and Rams on Saturday night or Patriots and Texans on Sunday, could become an endangered species as a half dozen teams are in varying stages of planning moves from outdoor stadiums to domes.

One of those is the Bears, who currently have suburban Arlington Heights and Gary, Ind., in a bidding war to replace Soldier Field. And that idea does not sit well with franchise legend Brian Urlacher. 

“I’m not a fan at all,” Urlacher told Jim Rome last week. “One of the few advantages they have is the weather. Nobody wants to go there in the winter. Our fans love it. Playing there, we enjoyed it because we knew it was the one thing we had to our advantage is the weather … I feel like teams from the West Coast coming up in the winter, teams from Florida, they don’t want to be in that weather. No one does.”

“I’m not a fan of the indoor [stadium],” Urlacher continued. “I know they want to get the Super Bowl, I know they want to get Final Fours. I understand all that, but I think you’re taking an advantage away from your football team.” 

In addition to the Bears, the Chiefs, Browns, Commanders, and Titans have plans to move from outdoor stadiums to domes. The Broncos are planning a retractable-roof stadium with a target date for the 2031 season. 

Renderings for new stadiums have frequently had noticeable similarities to recent facilities like SoFi in Greater Los Angeles, U.S. Bank in Minneapolis, and Allegiant in Las Vegas, and some fans have wondered whether homogeneity and shelter from the elements are actually going to come at the detriment of the competition.

“Football is supposed to be played outdoors. ‘Just Say No’ to any more domed, fixed roof stadiums,” the FB Helmet Guy wrote on X/Twitter over the weekend, responding to a gorgeous shot of Patriots quarterback Drake Maye connecting with receiver Kayshon Boutte on a touchdown as snow is heavily falling.

Wisconsin sports radio host Grant Bilse reacted on his show last week after renderings of a new Commanders stadium were released by the team. 

“I’m not saying it’s a bad stadium. It looks beautiful, and will no doubt be an upgrade from FedEx Field. It’ll be cool,” Bilse said. “Why are all the stadiums built post-AT&T Stadium—SoFi, Allegiant—they’re all the same. They’re all the same! You could look at this rendering for the Washington stadium. The columns! They’re all unique, and they’re fitting the locale! O.K., the columns look nice, but it’s another stadium with a translucent roof. Football’s an outside sport! Football is meant to be played outside!” 

An NFL spokesperson declined to make someone from the league available for comment about all of the planned domes, saying that these decisions are left up to the clubs. 

Financial Considerations

There are obvious business considerations for why franchises are switching to domes. It’s easier to sell tickets, particularly to luxury buyers, when they’re shielded from adverse weather. As Urlacher alluded to, team owners aspire to host big events like Super Bowls and the Final Four in their stadiums. You can also host big concerts in the winter. Stadium maintenance costs could be lower. 

Regarding the retractable dome being planned in Denver, the NFL spokesperson said it would be up to the team whether to keep it open or closed during the regular season and in the wild-card and divisional playoff rounds. The team just has to make its decision 90 minutes before kickoff.

However, for conference championship games and the potential Super Bowl, the decision is “solely at the discretion of [commissioner Roger Goodell],” the spokesperson said. During games that begin within an open roof, referees, in consultation with the stadium manager and league office, can order it closed during the game due to “hazardous conditions” or precipitation up until the last five minutes of the first quarter.

While a half dozen teams are in the process of switching to domes, there are still a fair number of stadiums where snow games can happen for the foreseeable future. The Bills are moving to a new outdoor stadium next season, and the Packers, Giants, Jets, Patriots, Steelers, Ravens, and Bengals do not appear to be planning new stadiums anytime soon.