## Facts

- Delisa Walton-Floyd, an elite U.S. track athlete, competed under doping rules administered by the sport’s national governing body and the international federation, which banned certain substances, including amphetamines.
- The United States Olympic Committee (USOC) distributed a card listing common banned substances and warning that the list was incomplete and that athletes remained responsible for checking all medications by calling a USOC hotline.
- Walton-Floyd’s husband/trainer obtained “Sydnocarb,” a product labeled in Russian with no translated instructions or listed ingredients.
- Walton-Floyd and her husband stated they called the USOC hotline and were told Sydnocarb was not on the banned list; the husband admitted the operator did not assure it was “safe” or give guarantees.
- At an international championship event, Walton-Floyd’s urine sample tested positive for amphetamines; a second split sample also tested positive.
- The international federation and national governing body sanctioned her, including suspension.
- Walton-Floyd sued the USOC in Texas state court for negligence, asserting the hotline advice and the USOC’s conduct violated duties arising from the federal Amateur Sports Act and caused her damages.

## Issues

1. Whether the Amateur Sports Act creates an express or implied private right of action allowing an athlete to recover damages from the USOC.
2. Whether a Texas negligence claim may proceed when the alleged duty and breach effectively rest on duties asserted to arise from the Amateur Sports Act and the USOC’s statutory role.

## Decision

- The court of appeals affirmed summary judgment for the USOC.
- The Amateur Sports Act does not create an implied private damages remedy for athletes against the USOC.
- A state-law negligence theory could not be used to obtain damages by indirectly enforcing federal statutory duties where Congress provided a specialized dispute-resolution structure but omitted a private damages remedy.
- The court also noted the hotline materials placed responsibility on the athlete and did not amount to a broad guarantee of completeness or accuracy for all substances.

## Legal Principles

- Courts will not imply a private right of action from a federal statute absent clear congressional intent reflected in the statute’s text and structure.
- A statutory grant that an entity may “sue and be sued” addresses legal capacity and does not itself create substantive causes of action for private damages.
- State tort claims are not permitted when they function as an end-run around Congress’s chosen federal scheme—particularly where Congress established centralized governance and dispute-resolution mechanisms and declined to authorize damages suits.
- Where an organization expressly disclaims completeness of informational materials and assigns primary compliance responsibility to athletes, allegations of negligent misadvice are less likely to support recognition of a broad duty.

## Conclusion

The court held that an athlete could not recover damages from the USOC based on alleged misstatements about banned substances because the Amateur Sports Act provides no implied private right of action and Texas negligence law could not be used to indirectly enforce statutory duties Congress did not make privately actionable.


Walton-Floyd v. United States Olympic Committee, 965 S.W.2d 35 (Tex. App.—Houston [1st Dist.] 1998)