The Court of Arbitration for Sport (CAS) case CAS 2000/A/310 involved an appeal by wrestler L. against the International Olympic Committee (IOC) following a doping violation at the 2000 Sydney Olympics. L. had won a gold medal in men’s freestyle wrestling but tested positive for nandrolone metabolites, specifically 19-norandrosterone, at a concentration of 23 ng/ml, well above the IOC threshold of 2 ng/ml. The IOC disqualified L., revoked his medal, and excluded him from the Games. L. appealed the decision, arguing procedural irregularities, questioning the reliability of the testing, and suggesting alternative explanations for the positive result, such as endogenous production or contaminated supplements.
The CAS panel upheld the IOC’s decision, emphasizing the strict liability principle under the Olympic Movement Anti-Doping Code (OMAC), which holds athletes responsible for any prohibited substances in their bodies, regardless of intent. The IOC initially proved the presence of nandrolone, shifting the burden to L. to rebut the presumption of doping. L. failed to demonstrate any significant procedural flaws, such as discrepancies in urine volume, chain of custody issues, or irregularities in the B-sample analysis. The panel found no scientific basis to challenge the reliability of the IOC-accredited laboratory’s findings, despite L.’s claims about potential endogenous production or supplement contamination.
The case also addressed procedural aspects, including whether L. was properly notified about the B-sample analysis. The panel ruled that the IOC complied with OMAC requirements, and minor irregularities did not invalidate the results. The International Federation of Associated Wrestling Styles (FILA) supported the IOC’s findings, confirming the validity of the doping control process. The CAS dismissed L.’s appeal, affirming the sanctions imposed by the IOC. The decision reinforced the strict liability framework in anti-doping regulations and the importance of rigorous testing protocols in maintaining fair competition.
L. argued that discrepancies in the recorded volume, pH level, and specific gravity of his urine sample cast doubt on the validity of the test results. However, the Panel found no material discrepancies, attributing minor differences to more precise laboratory measurement techniques. Expert testimony supported this conclusion, and L. provided no counterevidence. The Panel also rejected L.’s claim that he was not personally notified of the B-sample analysis, ruling that the IOC Medical Commission followed the correct procedure by notifying the German Chef de Mission, as required by the OMAC.
Regarding the scientific reliability of the 19-norandrosterone threshold, the Panel upheld the IOC’s established rule that any concentration above 2 ng/ml in males constitutes a positive finding. The Panel emphasized its role in interpreting and applying existing rules rather than questioning their scientific basis, provided they align with Swiss law. L. challenged the threshold’s reliability, citing expert opinions suggesting endogenous production could exceed the limit. However, the Panel found insufficient evidence to refute the IOC’s threshold, relying instead on published studies and the experience of accredited laboratories.
The Panel acknowledged the challenges faced by the IOC and sports federations in combating doping, recognizing the need for rules based on the best available science, even if incomplete. It concluded that the IOC’s 2 ng/ml threshold for 19-norandrosterone, as applied in this case, provided reliable evidence of exogenous nandrolone administration. The Panel rejected L.’s argument that extreme dehydration and rapid rehydration could explain the elevated levels, citing expert testimony that such conditions would likely decrease, not increase, the metabolite’s concentration.
The Panel also dismissed L.’s speculation that injuries or contaminated supplements could explain the results. While L. cited injuries, he provided no scientific proof linking them to the metabolite levels. The Panel noted that L.’s negative tests before and after the Olympics were irrelevant, as nandrolone is rapidly metabolized. Finally, L. failed to provide evidence of consuming contaminated supplements or medication, unlike other cases where such claims were substantiated.
The Panel upheld the doping violation, finding the IOC’s evidence reliable and L.’s arguments unsubstantiated. It underscored the need for more robust scientific research to strengthen doping control measures while recognizing the difficulties in maintaining fair competition in elite sports. The ruling reinforces the zero-tolerance approach to doping in sports and the importance of athlete education regarding the risks of contaminated products.