Saturday, November 9, 2013

Reynolds v. International Amateur Athletic Federation case brief

Reynolds v. International Amateur Athletic Federation case brief summary
841 F.Supp. 1444 (1992)

Plaintiff amateur athlete filed a motion to convert a prior temporary restraining order into a preliminary injunction against defendant International Amateur Athletic Federation (IAAF), which refused to appear based upon its belief that personal jurisdiction was lacking over it. The Athletics Congress of the U.S.A., Inc. (TAC) and three other amateur athletes intervened as defendants. The United States Olympic Committee appeared as amicus curiae.

The IAAF suspended the amateur athlete after he tested positive for the anabolic steroid nandrolone following an international track and field competition. About one week later, the athlete took a second drug test that was negative for steroid use. The IAAF opposed the temporary restraining order but did not participate in the preliminary injunction hearing.

  • As a preliminary matter, the court held that the IAAF was subject to personal jurisdiction under the "transacting business" and "tortious activity" provisions of Ohio's long-arm statute, namely Ohio Rev. Code Ann. § 2307.382(A)(1), (3)-(4), (6) & (C). 
  • Moreover, the exercise of jurisdiction over the IAAF comported with the dictates of due process. Further, under Fed. R. Civ. P. 12(h)(1), the IAAF waived its right to contest the exercise of personal jurisdiction. 
  • On the merits, the court held that the athlete was entitled to a preliminary injunction because he showed that, in the absence of such injunction, he would have been irreparably harmed and that such harm outweighed any harm others might suffer. 
  • The athlete also showed that the public interest would have been furthered and that he was likely to succeed on the merits.

The court granted the amateur athlete's motion for a preliminary injunction restraining the IAAF and the TAC from threatening to impede or to interfere with his ability to compete in all international and national amateur track and field competitions due to a failed drug test. The IAAF and the TAC also were enjoined from threatening to suspend or contaminate any other athlete who competed with the athlete.

Suggested Study Aid For Sports Law

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