DeFrantz v. United States Olympic Committee
1980 U.S. Dist. LEXIS 14024, 492 F. Supp. 1181 (1980)
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Rule of Law:
The United States Olympic Committee (USOC), as a private entity, possesses the statutory authority to decide against sending an American team to the Olympic Games for reasons beyond purely sports-related considerations, and such a decision, even if influenced by government persuasion, does not constitute state action nor infringe upon any implied constitutional right of athletes to participate.
Facts:
- On December 27, 1979, the Soviet Union invaded Afghanistan, leading to international condemnation and humanitarian concerns.
- President Carter deemed the invasion a threat to world peace and proposed a boycott of the 1980 Summer Olympic Games scheduled to be held in Moscow as part of broader sanctions against the Soviet Union.
- President Carter wrote to the USOC President and publicly stated that he would not support sending American athletes to Moscow unless Soviet forces withdrew from Afghanistan.
- Both the U.S. House of Representatives and the Senate passed resolutions opposing participation by United States athletes in the Moscow Games if Soviet troops remained in Afghanistan.
- President Carter and other Executive Branch officials engaged in a campaign of persuasion, including a telegram from the President and an address by Vice President Mondale, urging the USOC to vote against sending an American team to Moscow, and allegedly threatened to revoke federal funding or tax-exempt status if they did not comply.
- On April 12, 1980, the USOC House of Delegates, following a secret ballot, passed a resolution by a vote of 1,604 to 798, stating that the USOC had decided not to send a team to the 1980 Summer Games in Moscow, citing the President's advice regarding national security.
- Twenty-five athletes and one member of the USOC Executive Board, Anita De-Frantz, desired to compete in the Moscow Olympics.
Procedural Posture:
- Plaintiffs (25 athletes and one member of the USOC Executive Board) filed an action in the United States District Court for the District of Columbia.
- Plaintiffs sought an injunction to bar the defendant USOC from carrying out its resolution not to send a team to the 1980 Summer Olympics in Moscow, along with declaratory relief.
- Defendant USOC and the United States (appearing as Amicus Curiae) moved to dismiss the action pursuant to Rule 12(b)(6), Fed.R.Civ.P., arguing that the plaintiffs failed to state a claim upon which relief could be granted.
- The District Court granted plaintiffs’ motion that a trial of the action on the merits be advanced and consolidated with the hearing for a preliminary and permanent injunction.
- The District Court heard oral argument on May 18, 1980, on the motions.
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Issue:
Does the United States Olympic Committee (USOC) violate the Amateur Sports Act of 1978 or abridge athletes' constitutional rights when it decides not to send an American team to the Olympic Games for non-sports-related reasons, particularly when influenced by presidential pressure?
Opinions:
Majority - United States District Court for the District of Columbia
No, the United States Olympic Committee did not violate the Amateur Sports Act of 1978 or abridge athletes' constitutional rights when it decided not to send an American team to the Olympic Games, even for non-sports-related reasons and despite presidential influence. The court first analyzed the statutory claims, finding that the Amateur Sports Act of 1978 did not deny the USOC the authority to decide against participating in the Olympics. The USOC, as the designated National Olympic Committee, derived its power from the International Olympic Committee (IOC) Rules, which explicitly state that representation includes the decision to participate. Congress, when enacting the Amateur Sports Act, was aware of this existing relationship and did not intend to limit the USOC's broad 'exclusive jurisdiction' over U.S. Olympic participation to only sports-related reasons. The 'sports-related' limitation in the Act applies specifically to national governing bodies sanctioning sub-Olympic competitions, designed to curb infighting among amateur athletic organizations, not to the USOC's overarching decision on Olympic participation itself. Furthermore, the court determined that the Act’s 'Athlete's Bill of Rights' provisions were intended to address jurisdictional disputes between athletic organizations and were not designed to create an individual, enforceable right for athletes to compete in the Olympic Games if the USOC decided against sending a team. Since no such statutory right existed, there was no implied private cause of action for the plaintiffs to enforce. Turning to the constitutional claims, the court concluded that the USOC’s decision was not 'governmental action' (state action). Although federally chartered, the USOC is a private organization that receives no federal funding and operates independently. The court applied the 'symbiotic relationship' test (from Burton v. Wilmington Parking Authority) and the 'close nexus' test (from Jackson v. Metropolitan Edison Co.) and found that the extensive governmental persuasion, even by the President, did not constitute the level of 'control' necessary to transform the USOC's independent, secret ballot decision into state action. Lastly, even if state action were present, the court found that the denial of the opportunity to compete in the Olympics did not abridge any constitutionally protected rights, such as liberty, self-expression, or the right to travel, refusing to broadly expand the scope of these rights to include participation in a specific amateur athletic competition.
Analysis:
This case significantly clarified the scope of the United States Olympic Committee's authority under the Amateur Sports Act of 1978, affirming its independence from direct governmental control regarding Olympic participation decisions, even when those decisions are influenced by national policy considerations. The ruling also narrowly interpreted the 'Athlete's Bill of Rights' within the Act, limiting its application to internal organizational disputes rather than creating an individual right to compete against a USOC decision not to send a team. Furthermore, the court reinforced a high bar for establishing 'state action' in cases involving private entities, particularly when governmental influence amounts to persuasion rather than direct control, underscoring the legal distinction between a private organization's independent decision-making and actions directly attributable to the state. This precedent highlights the limits of federal court intervention in the internal affairs of chartered private organizations and in disputes involving claims of broad constitutional rights tied to participation in specific extracurricular activities.
