The case revolves around a dispute between the Netherlands Antilles Olympic Committee (NAOC) and the International Association of Athletics Federations (IAAF), along with the United States Olympic Committee (USOC), concerning the disqualification of athlete Churandy Martina during the 2008 Beijing Olympics. Martina initially finished second in the men's 200-meter final but was later disqualified for a lane violation following a protest by the USOC. The IAAF Jury of Appeal upheld the protest, leading the NAOC to file an appeal with the Court of Arbitration for Sport (CAS), seeking to reinstate Martina's silver medal. The case was initially referred to the CAS ad hoc Division during the Olympics but was later transferred to regular CAS procedures due to its complexity and the involvement of multiple parties.
The NAOC argued that the protest was invalid and that Martina's disqualification was unjust, while the USOC and USA Track & Field (USATF) defended the IAAF's decision, asserting it was justified under the rules. The USOC contended that the NAOC's appeal attempted to overturn a "field of play" decision, which is typically not subject to review unless there is evidence of bad faith or procedural irregularities. The key legal issue centered on CAS's jurisdiction to review decisions made by the IAAF Jury of Appeal, particularly those deemed "field of play" decisions. While the IAAF's rules stated such decisions were final, the Olympic Charter grants CAS broad jurisdiction over Olympic disputes, which cannot be limited by the internal rules of international federations.
The Sole Arbitrator, Prof. Luigi Fumagalli, noted that CAS could review such decisions only in exceptional circumstances, such as evidence of bad faith or procedural flaws. The case highlighted the tension between the autonomy of sports federations and CAS's authority under the Olympic Charter. The NAOC challenged the procedural validity of the protest and the fairness of the decision, while the respondents maintained the disqualification was proper. The arbitrator emphasized that the "field of play" doctrine prevents reviewing procedural decisions made during the event, including whether protests were timely filed or authorized. The arbitrator found no evidence of bad faith, corruption, or procedural violations that would justify overturning the decision.
Ultimately, the arbitrator dismissed NAOC's appeal, upholding the IAAF Jury of Appeal's decision. The ruling confirmed that the appeal failed on all grounds, reinforcing the principle that technical and procedural sports decisions should generally remain beyond judicial interference unless exceptional circumstances are proven. The case underscored the limited scope for challenging field-of-play decisions and the importance of respecting the autonomy of sports federations in managing competitions. The Court of Arbitration for Sport dismissed the appeal and upheld the original decision, concluding the dispute.