The case involves a dispute between the Liberia Football Association (LFA) and FIFA, adjudicated by the Court of Arbitration for Sport (CAS), concerning the enforcement of a settlement agreement between the LFA and a football coach. The dispute originated from the LFA's failure to comply with a prior FIFA decision ordering payment of outstanding salary, indemnity, and compensation to the coach. In May 2014, the LFA and the coach reached a settlement, wherein the LFA agreed to pay a reduced amount in installments and offer the coach a new contract. The agreement stipulated that non-payment would render the settlement null and void. The LFA made the initial payments, and the coach's representative informed FIFA that the matter was resolved. However, the coach later contested this, claiming the LFA had not fully complied, prompting FIFA's Disciplinary Committee (DC) to intervene.
The LFA argued that the FIFA DC lacked jurisdiction to assess compliance with the settlement, as this required legal analysis beyond its scope. The CAS panel agreed, stating the DC's authority is limited to clear cases of non-compliance and cannot adjudicate disputes requiring detailed legal examination. The panel emphasized that the DC cannot declare a settlement null and void or revert to the original contract as the basis for its decision. Since the appealed decision was made by a body lacking jurisdiction, the CAS panel ruled it could not decide the matter without a prior decision from the competent FIFA body. The case was referred back to FIFA for proper adjudication, even though neither party had explicitly requested this.
The settlement required the LFA to pay $30,000 in installments and an additional $60,000 if no new contract was offered. The coach received the initial payments but later signed a contract in Egypt, making him unable to accept the LFA's offer. The coach argued the settlement was null due to the LFA's failure to meet its obligations, including the additional payment. The FIFA DC ruled in favor of the coach, imposing a CHF 10,000 fine on the LFA and granting a 30-day grace period for payment. The LFA appealed to CAS, contending the matter was settled and the DC overstepped its jurisdiction.
The CAS panel examined whether the FIFA DC had the authority to assess compliance with the settlement under Article 64 of the FIFA Disciplinary Code. It concluded the DC overstepped its jurisdictional limits by interpreting the settlement's terms, which required nuanced legal analysis. The panel highlighted ambiguities in the settlement's wording and found such matters fall outside the DC's scope. The panel set aside the appealed decision and referred the case back to the FIFA DC, instructing it to suspend proceedings and refer the contractual dispute to the appropriate FIFA body for resolution.
The ruling underscores the importance of jurisdictional boundaries within FIFA's disciplinary framework, ensuring contractual disputes are resolved by the appropriate adjudicative bodies before disciplinary measures are enforced. The case clarifies that disciplinary committees should not overreach their statutory mandates, reinforcing procedural correctness and legal clarity in resolving conflicts within international football governance. The CAS decision emphasizes the need for proper allocation of authority to maintain fairness and adherence to procedural rules.