Reynolds v. International Amateur Athletic Federation

World track and field record holder in the 400 meters, Harold “Butch” Reynolds (plaintiff), tested positive for the anabolic steroid nandrolone after a urine sample was taken at an event in Monte Carlo, Monaco in August 1990. As a result, Reynolds was suspended from competition by the International Amateur Athletic Federation (IAAF) (defendant) for two years which meant that he would not be able to compete in the 1992 Olympic Games in Barcelona, Spain. Reynolds brought suit against the IAAF in his home state of Ohio, arguing that the test results were erroneous, based in part on the fact that a urine sample taken one week prior to the Monte Carlo sample had tested negative for steroids. The district court dismissed Reynolds’ suit on the ground that he was first required to exhaust the athletic system’s administrative process. Thereafter, Reynolds sought an arbitration hearing pursuant to the Amateur Sports Act of 1978 and the constitution of the U.S. Olympic Committee (USOC). Following the hearing, Reynolds was exonerated from any wrongdoing related to his urine test. However, the IAAF refused to accept the ruling because it had not complied with the procedures under IAAF Rule 59, which were administered in the U.S. by the TAC. Thus, Reynolds asked the TAC to conduct a hearing which, after a hearing, also exonerated Reynolds. Still, the IAAF refused to accept the TAC’s finding and under its Rule 20, ordered another arbitration of the dispute. After a two-day hearing, and after two hours of deliberation, a three-member panel issued a seven-page opinion finding Reynolds guilty. Reynolds returned to district court in Ohio, suing the IAAF for breach of contract, defamation, tortious interference with a business relationship, and denial of contractual due process. The IAAF responded that an American court had no jurisdiction over the entity and refused to participate in any proceedings.