## Facts

- Harry L. “Butch” Reynolds, an Ohio resident and elite 400-meter sprinter, competed in an international meet in Monte Carlo, Monaco, and submitted to post-race drug testing under international track rules.
- A Paris laboratory reported trace amounts of the banned steroid Nandrolone in both urine samples; the International Amateur Athletic Federation (IAAF), a London-based unincorporated association, imposed a two-year ban from international competition.
- The IAAF issued a press release stating Reynolds tested positive and that a follow-up analysis confirmed metabolites of Nandrolone.
- Reynolds disputed the test results and pursued relief through U.S. amateur sports processes, including arbitration; the arbitration exonerated him, but the IAAF refused to recognize that outcome and maintained the suspension.
- Reynolds sued the IAAF in the Southern District of Ohio for damages and injunctive relief (including claims such as defamation and breach of contract) to permit him to compete.
- The IAAF did not initially appear, asserting the Ohio federal court lacked jurisdiction; the district court entered a default judgment, awarded approximately $27.3 million, and entered permanent injunctive relief against enforcing the suspension.
- Reynolds initiated Ohio garnishment proceedings against U.S. sponsors alleged to owe money to the IAAF; the IAAF then appeared specially to quash garnishment and vacate the default judgment and injunction as void for lack of jurisdiction.
- The district court denied the IAAF’s motion, and the IAAF appealed.

## Issues

1. Whether an Ohio federal court could exercise personal jurisdiction over the IAAF consistent with due process where the drug test, disciplinary decision, and press release occurred abroad and the IAAF had no offices or events in Ohio.
2. Whether the IAAF’s relationship with the U.S. national governing body for track and field (TAC) could be treated as an agency relationship sufficient to impute forum contacts to the IAAF.
3. Whether alleged reputational and economic effects in Ohio from an internationally distributed press release established purposeful direction toward Ohio.
4. Whether the IAAF waived its personal-jurisdiction objection by not appearing before default and later appearing to contest garnishment and jurisdiction.
5. If personal jurisdiction was lacking, whether the default judgment, permanent injunction, and garnishment proceedings were void and required vacatur.

## Decision

- The Sixth Circuit reversed the order denying the IAAF’s motion and held the Ohio federal court lacked personal jurisdiction over the IAAF.
- The court concluded the IAAF did not have sufficient minimum contacts with Ohio and had not purposefully availed itself of the forum in connection with Reynolds’s claims.
- The court rejected attempts to base jurisdiction on Reynolds’s Ohio residency and in-forum injury, the IAAF’s membership relationship with TAC, and the press release’s downstream effects in Ohio.
- The court held the IAAF did not waive its jurisdictional defense by appearing solely to contest jurisdiction and quash garnishment.
- Because the district court lacked personal jurisdiction, the default judgment (including the damages award and permanent injunction) was void; the garnishment proceedings could not stand, and the claims against the IAAF were ordered dismissed.

## Legal Principles

- A court may exercise personal jurisdiction over a nonresident defendant only if the defendant has minimum contacts with the forum and the exercise of jurisdiction comports with traditional notions of fair play and substantial justice.
- Minimum contacts require purposeful availment or purposeful direction; a plaintiff’s residency and in-forum injury, without forum-directed conduct by the defendant, do not establish jurisdiction.
- Forum contacts are not imputed from a domestic entity to a foreign association absent a showing of an agency relationship sufficient to treat the domestic entity’s conduct as the foreign defendant’s forum conduct.
- For tort claims premised on reputational harm, an internationally oriented statement made abroad does not, by downstream effects alone, constitute conduct aimed at the forum for due process purposes.
- A defendant may appear to challenge personal jurisdiction and related enforcement efforts without waiving the jurisdictional objection when the appearance is limited to contesting jurisdiction.
- A judgment entered without personal jurisdiction is void and subject to being set aside; enforcement measures dependent on that judgment must also be quashed.

## Conclusion

The Sixth Circuit held that Ohio courts could not exercise personal jurisdiction over a foreign sports governing body for overseas doping enforcement and related publicity where the defendant lacked forum-directed contacts, rendering the default judgment, injunction, and garnishment proceedings void.


Reynolds v. Int'l Amateur Athletic Fed'n, 23 F.3d 1110 (6th Cir. 1994), cert. denied, 513 U.S. 962 (1994)