## Facts

- Liang Ren-Guey, an athlete selected by the National Olympic Committee (NOC) of the Republic of China (Taiwan), qualified to compete in the 1980 Winter Olympic Games at Lake Placid.
- Lake Placid 1980 Olympic Games, Inc. (a New York not-for-profit) served as the host organizing committee under the Olympic Charter and acted as an operational surrogate for the International Olympic Committee (IOC).
- Under the Olympic Charter, participants and organizations involved in the Games accept the IOC’s “supreme authority,” and the IOC has final authority over questions concerning the Games.
- The IOC long confronted the “two Chinas” dispute regarding how Taiwanese athletes may be identified and what national symbols may be used; similar restrictions occurred at prior Olympics.
- In 1979, the IOC decided both the People’s Republic of China (PRC) and Taiwan could participate, but the IOC Executive Board permitted the PRC NOC to use the PRC’s official symbols while requiring Taiwan’s NOC to change its name and submit alternative flag, anthem, and emblem; Taiwan’s NOC complied under protest.
- Ren-Guey sued the host organizing committee seeking a permanent injunction halting the Lake Placid Games unless he was allowed to compete under the Republic of China’s official name, flag, emblem, and anthem.
- The United States Attorney General was permitted to file a statement of interest noting the dispute’s sensitivity to U.S. foreign relations following U.S. recognition of the PRC and withdrawal of recognition from the Republic of China.

## Issues

1. Whether a state court should adjudicate and override Olympic governance decisions about national designation and symbols for participating athletes.
2. Whether a court may issue injunctive relief effectively requiring the host committee to disregard IOC directives, notwithstanding foreign-relations implications and the disruptive effect of halting the Games.

## Decision

- The Appellate Division reversed the trial court’s order granting relief to Ren-Guey.
- The court denied the requested permanent injunction and declined to compel the host committee to permit competition under the Republic of China’s official symbols.
- The Games were allowed to proceed under the IOC’s conditions governing Taiwan’s name and symbols.

## Legal Principles

- Participants in the Olympic Games are bound by the Olympic Charter structure that vests final authority over Games-related questions in the IOC.
- Courts will generally refrain from intervening in internal governance decisions of a private international sports organization where participation is voluntary and conditioned on acceptance of that organization’s rules.
- Injunctive relief is disfavored where it would impose disproportionate harm on third parties and disrupt major international events.
- Courts avoid remedies that would entangle the judiciary in matters closely connected to foreign relations and executive-branch policy.

## Conclusion

The Appellate Division refused to enjoin the 1980 Lake Placid Olympics to compel use of Taiwan’s official national symbols, emphasizing the IOC’s charter-based authority, the limited role of courts in Olympic governance disputes, the extraordinary disruption threatened by the requested injunction, and the foreign-relations implications of the relief sought.


Ren-Guey v. Lake Placid 1980 Olympic Games, Inc., 72 A.D.2d 439, 424 N.Y.S.2d 535 (N.Y. App. Div. 3d Dep’t 1980)