## Facts

- Lance Armstrong, a professional cyclist, was charged by the United States Anti-Doping Agency (USADA) in 2012 with multiple anti-doping rule violations tied to an alleged years-long doping scheme.
- USADA’s notice alleged prohibited conduct including use and trafficking of banned substances and methods (including EPO, blood transfusions, and testosterone), supported by collected samples and witness testimony.
- Under the USADA Protocol, Armstrong was offered a choice to contest the charges through arbitration before an American Arbitration Association/North American Court of Arbitration for Sport panel or accept sanctions.
- Potential sanctions included lifetime ineligibility from certain competitions and forfeiture of results, medals, points, and prizes from the relevant period.
- Armstrong filed suit in federal district court seeking declaratory and injunctive relief (and damages), asserting that USADA lacked authority to proceed, that he had not validly agreed to arbitrate with USADA, and that the process violated Fifth Amendment and common-law due process.
- USADA and its CEO (sued in his official capacity) moved to dismiss for lack of jurisdiction and failure to state a claim.

## Issues

1. Whether USADA’s charging and arbitration procedures violated Armstrong’s Fifth Amendment and common-law due process rights.
2. Whether the federal court had subject-matter jurisdiction to intervene in an ongoing anti-doping proceeding and related eligibility determinations, and whether equitable doctrines counseled against intervention.
3. Whether Armstrong had agreed to arbitrate disputes under the USADA Protocol and was required to pursue arbitration (including questions of arbitrability and USADA’s authority) before seeking judicial relief.

## Decision

- The court granted defendants’ motion to dismiss and dismissed the action without prejudice.
- The court rejected Armstrong’s due process claims on the merits, holding the arbitral framework provided adequate procedural protections.
- The court held it lacked jurisdiction over Armstrong’s remaining claims or, alternatively, declined to grant equitable relief that would interfere with the arbitration-centered dispute-resolution scheme.
- The court treated challenges to USADA’s authority, the scope of charges, and applicable rules as matters to be addressed in the arbitration process in the first instance.

## Legal Principles

- Where a structured sports arbitration system exists for anti-doping and eligibility disputes, federal courts generally will not provide preemptive judicial review that would bypass or disrupt arbitration.
- Arbitral procedures that provide notice, a meaningful opportunity to be heard, the ability to present evidence and cross-examine witnesses, and a neutral decisionmaker can satisfy due process for purposes of resisting injunctive relief.
- An athlete’s repeated participation under a sport’s licensing and governance regime may incorporate anti-doping protocols and mandatory arbitration provisions, binding the athlete to arbitrate covered disputes.
- Failure to pursue available arbitration remedies can bar or weaken judicial attempts to halt ongoing disciplinary proceedings, particularly when arbitration can address both merits and threshold authority questions.

## Conclusion

The court dismissed Armstrong’s suit without prejudice, concluding that the arbitration process supplied sufficient procedural safeguards and that the court should not (or could not) intervene in the anti-doping and eligibility dispute before arbitration occurred.


Armstrong v. United States Anti-Doping Agency, 886 F. Supp. 2d 572 (W.D. Tex. 2012)