The case of Olga Stulneva v. the International Olympic Committee (IOC) before the Court of Arbitration for Sport (CAS) involved allegations of doping and tampering with doping control procedures during the 2014 Sochi Winter Olympics. The CAS panel examined the evidence presented by the IOC, which included forensic analyses, witness testimonies, and reports such as the McLaren Reports, which detailed a state-sponsored doping scheme in Russia. The IOC alleged that Stulneva participated in a urine-swapping scheme, used prohibited substances, and tampered with doping controls, citing her inclusion on the "Duchess List" and forensic evidence like scratch marks on sample bottles and abnormal sodium levels in urine samples.
The panel applied the "comfortable satisfaction" standard of proof, requiring cogent evidence to establish anti-doping rule violations (ADRVs). While acknowledging the existence of a broader doping scheme, the panel found insufficient direct evidence linking Stulneva to specific violations. Key issues included the reliability of Dr. Grigory Rodchenkov's testimony, the validity of the Duchess List, and the forensic analysis of sample bottles. The panel noted inconsistencies in Rodchenkov's accounts and the lack of corroborating evidence for Stulneva's personal involvement in urine substitution or prohibited substance use. Forensic evidence, such as multiple T marks on bottles, was deemed inconclusive due to methodological flaws and the absence of tests on urine-filled bottles.
The panel concluded that the IOC failed to meet its burden of proof under Articles 2.2, 2.5, and 2.8 of the World Anti-Doping Code (WADC), which address prohibited methods, tampering, and complicity, respectively. It emphasized that while the doping scheme may have existed, individual liability required clear evidence of Stulneva's participation. Without such proof, the panel ruled in Stulneva's favor, annulling the IOC's decision and reinstating her results from the Sochi Games. The ruling underscored the importance of direct evidence in doping cases and the need to balance rigorous anti-doping enforcement with fair adjudication. The panel also dismissed due process claims as moot and ordered each party to bear its own costs, retaining only a nominal CAS fee. The decision highlighted the challenges of proving individual involvement in systemic doping and reaffirmed the principle that athletes cannot be sanctioned without conclusive evidence of wrongdoing.