The case involves Joshua Taylor, a rugby union player, who appealed against a doping violation decision by World Rugby after testing positive for a metabolite of dehydrochlormethyl-testosterone (DHCMT), a prohibited substance, during an out-of-competition test in May 2016. Taylor argued that the substance entered his system unintentionally through a supplement called Deca-Plexx, which he had taken in 2014 to improve his appearance for a social event, not for athletic performance. The Court of Arbitration for Sport (CAS) panel reviewed the case, focusing on whether Taylor was subject to anti-doping rules, the source of the prohibited substance, and the level of fault or negligence involved.
Key legal principles outlined by the panel included the strict liability rule, which holds athletes responsible for any prohibited substances in their system, regardless of intent. To prove unintentional use, Taylor needed to demonstrate the source of the substance with a balance of probabilities (over 50% likelihood). The panel acknowledged Taylor’s lack of intent to cheat, citing his young age (17 at the time of ingestion), inexperience, and absence of anti-doping education. However, they criticized his failure to verify the supplement’s contents, noting his careless behavior despite aspiring to professional rugby. While mitigating factors were considered, his negligence was deemed significant, warranting a sanction at the higher end of the permissible range.
Taylor’s defense relied on circumstantial evidence, including the manufacturer Alpha Labs’ history of producing contaminated supplements and expert testimony suggesting the M3 metabolite could remain detectable for ten months. The panel accepted that Deca-Plexx was the likely source but emphasized this conclusion was fact-specific and not a precedent. World Rugby contested Taylor’s claims, arguing alternative explanations for the positive test and maintaining that he failed to prove unintentional use conclusively. The panel ultimately found Taylor committed an anti-doping rule violation but reduced the sanction from four years to two years, reflecting his lack of intent but significant fault.
The decision underscores the strict liability principle in anti-doping regulations, highlighting athletes’ responsibility to ensure their supplements are free of banned substances. It also illustrates the challenges athletes face in proving unintentional violations, particularly when supplement contamination is alleged. The panel’s ruling balanced Taylor’s personal circumstances with the objective standard of care required, concluding with a 24-month suspension starting from his provisional suspension date in June 2016. The case serves as a reminder of the importance of due diligence and education in avoiding doping violations, even for inexperienced athletes.