## Facts

- Anita DeFrantz and other athletes eligible and intending to compete in the 1980 Summer Olympics sued the United States Olympic Committee (USOC) after it voted not to send a U.S. team to the Moscow Games.
- On April 12, 1980, the USOC House of Delegates adopted a resolution declining to participate in the 1980 Olympics, following the Soviet Union’s invasion and continued occupation of Afghanistan and related U.S. foreign policy efforts to boycott the Games.
- The International Olympic Committee (IOC) governs the Olympic movement and recognizes National Olympic Committees (NOCs) as the sole authorities for national representation at the Games; the USOC is the U.S. NOC and is federally chartered.
- Plaintiffs alleged the USOC’s decision resulted from strong governmental pressure, including threatened loss of federal funding, tax benefits, and other adverse actions if the USOC did not support the boycott.
- Plaintiffs sought preliminary and permanent injunctive relief to block implementation of the boycott resolution and declaratory relief that the USOC exceeded statutory authority and violated constitutional rights.
- The district court resolved the case on the pleadings, concluding plaintiffs failed to state a claim.

## Issues

1. Whether the USOC exceeded its authority under the Amateur Sports Act of 1978 by deciding not to send a U.S. team to the 1980 Moscow Olympics.
2. Whether the USOC’s boycott decision constituted state action attributable to the federal government, permitting constitutional claims against the USOC.
3. Whether the Amateur Sports Act created a judicially enforceable individual right for athletes to compete in the Olympic Games, limiting the USOC’s discretion.

## Decision

- The court denied injunctive and declaratory relief and dismissed the action for failure to state a claim.
- The court held the USOC acted within its statutory and organizational authority in choosing not to send a team.
- The court held the USOC’s decision was not state action, notwithstanding substantial governmental encouragement and political pressure.
- The court held the Amateur Sports Act did not create an enforceable individual right to compel Olympic participation.

## Legal Principles

- A federally chartered private corporation does not become a state actor solely because it receives federal benefits or faces intense governmental persuasion; state action requires sufficient governmental control or legal compulsion over the challenged decision.
- The Amateur Sports Act primarily addresses governance and jurisdictional organization in amateur sports and does not, without clear statutory language, confer a private entitlement to participation in the Olympic Games.
- The USOC, as the recognized U.S. NOC, has broad discretion to determine whether and how the United States will be represented at a given Olympic Games.

## Conclusion

The court upheld the USOC’s refusal to send a team to the 1980 Moscow Olympics, concluding the decision fell within the USOC’s discretion under federal sports governance law, was not attributable to the government for constitutional purposes, and could not be overridden by athletes through an asserted statutory right to compete.


DeFrantz v. U.S. Olympic Comm., 492 F. Supp. 1181 (D.D.C. 1980)