## Facts

- Matt Lindland and Keith Sieracki competed for the United States’ 76‑kilogram Greco‑Roman wrestling berth for the 2000 Olympic Games.
- At the June 24, 2000 Olympic trials, officials declared Sieracki the winner of the decisive bout, and USA Wrestling treated him as the nominee.
- After USA Wrestling denied Lindland relief through internal processes, Lindland initiated arbitration under the Ted Stevens Olympic and Amateur Sports Act.
- Arbitrator Daniel T. Burns ordered the decisive bout re‑wrestled by August 14, 2000; Lindland won the rematch by unanimous decision.
- USA Wrestling nevertheless continued to treat Sieracki as its nominee and listed Lindland only as an alternate.
- Lindland moved in federal court to confirm and enforce the Burns award under the Federal Arbitration Act; the award was confirmed, and USA Wrestling appealed.
- The Seventh Circuit previously held that enforcement of the Burns award entitled Lindland to be USA Wrestling’s nominee to the USOC.
- Sieracki obtained a second arbitration award from a different arbitrator (Campbell) directing USA Wrestling to nominate Sieracki based on the original bout.
- After USA Wrestling sent mixed signals to the USOC, the Seventh Circuit issued mandamus directing immediate and unconditional implementation of the Burns award.
- USA Wrestling then submitted Lindland’s name to the USOC, but the USOC refused to accept him, asserting the nomination was untimely because Sieracki had already been forwarded to the IOC.
- Lindland sought relief compelling the USOC to recognize him; Sieracki brought a separate action seeking recognition of the Campbell award; the appeals were consolidated.

## Issues

1. Whether the USOC was required to accept USA Wrestling’s nomination of Lindland made pursuant to a judicially confirmed arbitration award.
2. Whether the USOC could refuse the nomination based on asserted Olympic entry deadlines after Sieracki’s name had been forwarded to the IOC.
3. Whether a later, conflicting arbitration award could justify noncompliance with a confirmed arbitration award and an appellate mandate.

## Decision

- The Seventh Circuit held that Lindland was entitled to be USA Wrestling’s nominee and that the USOC had to accept him as the U.S. entrant in the 76‑kilogram Greco‑Roman event.
- The court rejected reliance on the later Campbell award, explaining that it could not override a confirmed award backed by a federal judgment and the court’s mandate.
- The court rejected the USOC’s untimeliness argument, finding it provided no lawful basis to disregard the nomination required by the confirmed award.
- Sieracki’s competing claim premised on the Campbell award was denied.

## Legal Principles

- A confirmed arbitration award under the FAA is enforceable as a federal judgment, and parties may not treat compliance as discretionary.
- When inconsistent arbitration awards exist, the award reduced to judgment controls for enforcement; a later, unreviewed award cannot supersede the judgment.
- Sports governing bodies and the USOC must honor team-selection results required by a confirmed award and appellate mandate; administrative timing concerns do not excuse noncompliance.
- Mandamus may issue to compel prompt adherence to an appellate mandate implementing a confirmed arbitration award.

## Conclusion

The court enforced the judicially confirmed Burns arbitration award and required the USOC to accept Lindland as the Olympic nominee, holding that neither a later conflicting arbitration award nor asserted entry-deadline concerns justified ignoring a federal judgment and mandate.


Lindland v. U.S.A. Wrestling Ass’n, 227 F.3d 1000 (7th Cir. 2000)