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. The IAAF is an unincorporated association based in London, England, and made up of track and field organizations representing 205 nations. 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 IAAF did not have any offices in the U.S. and held no track events in Ohio. The district court granted Reynolds an injunction barring the enforcement of the suspension and subsequently entered a default judgment against the IAAF, awarded Reynolds $27.3 million in damages, and made the earlier injunction permanent. In order to enforce the monetary judgment, Reynolds garnished money that U.S. corporations owed the IAAF for various sponsorship deals. Thereafter, the IAAF appeared in court to quash the garnishment proceedings and to set aside the entire judgment on the basis that the court lacked personal jurisdiction over it. The district court denied IAAF’s motion and it appealed.