## Facts

- Harry L. (“Butch”) Reynolds Jr., an elite U.S. amateur 400-meter runner, provided a urine sample after an international meet in Monte Carlo on August 12, 1990.
- Reynolds was notified on October 18, 1990 that the sample tested positive for nandrolone; the international federation suspended him pending action by the U.S. national governing body.
- Reynolds initially filed suit in federal court; the action was dismissed for failure to exhaust internal sport dispute procedures.
- Reynolds then pursued arbitration under U.S. Olympic and amateur-sport procedures; an arbitration panel exonerated him, finding substantial doubt about the drug test’s reliability.
- The U.S. national governing body also concluded Reynolds should not be sanctioned.
- The international federation rejected those outcomes as noncompliant with its rules and directed a further arbitration under its authority.
- After a brief hearing, the federation-directed panel found Reynolds guilty and the federation imposed a two-year suspension, jeopardizing his ability to compete for the 1992 Olympics.
- Reynolds sued in federal district court asserting breach of contract, defamation, tortious interference with business relations, and denial of contractual due process, and sought to enjoin enforcement of the suspension.
- The international federation refused to appear, asserting the court lacked personal jurisdiction; the court entered a temporary restraining order and held an evidentiary hearing on whether to issue a preliminary injunction.

## Issues

1. Whether the court could exercise personal jurisdiction over the international federation based on its contacts with U.S. athletics and its regulation of a U.S. athlete’s eligibility.
2. Whether Reynolds satisfied the standards for a preliminary injunction (likelihood of success, irreparable harm, balance of harms, and public interest) to bar enforcement of the suspension pending a merits decision.
3. Whether, and to what extent, the court should give effect to the federation’s disciplinary process in light of earlier U.S. arbitration and national-governing-body determinations exonerating Reynolds.

## Decision

- The court held it had personal jurisdiction over the international federation because it purposefully conducted activities in the United States affecting U.S. athletes and competitions, and the dispute arose from those contacts.
- The court granted Reynolds’s motion to convert the temporary restraining order into a preliminary injunction.
- The injunction restrained the international federation and the U.S. national governing body from enforcing the suspension or otherwise interfering with Reynolds’s eligibility to compete based on the August 12, 1990 test while the case proceeded.
- The court found Reynolds showed a substantial likelihood of success on at least some claims, particularly those tied to the disputed reliability of the test and the handling of governing-body procedures.
- The court found irreparable harm because exclusion from Olympic-qualification and elite competitions during a limited athletic window could not be adequately remedied by money damages.
- The balance of harms favored Reynolds because the injunction preserved the status quo and did not finally resolve the doping charge.
- The public interest favored interim relief given serious questions regarding fairness and reliability, while recognizing the importance of anti-doping enforcement.

## Legal Principles

- A foreign sports governing body may be subject to personal jurisdiction in a U.S. forum when it has purposeful, systematic contacts with U.S. athletics and directly regulates eligibility of U.S.-based athletes.
- Preliminary injunctive relief may be warranted where an athlete faces time-sensitive loss of unique competition opportunities (including Olympic participation) that are not readily compensable by damages.
- Courts may intervene in sports-discipline disputes at the interim-relief stage when there are substantial questions about contractual rights, procedural regularity, and the reliability or fairness of the disciplinary basis, without finally adjudicating the underlying eligibility dispute.

## Conclusion

The court exercised personal jurisdiction over the international federation and issued a preliminary injunction preventing enforcement of Reynolds’s doping suspension, allowing him to compete while his civil claims challenging the suspension and related procedures were litigated.


Reynolds v. Int’l Amateur Athletic Fed’n, 841 F. Supp. 1444 (S.D. Ohio 1992)