The case of Lucas Mahias v. Fédération Internationale de Motocyclisme (FIM) before the Court of Arbitration for Sport (CAS) revolved around a dispute arising from the 2018 FIM Supersport World Championship. Mahias was disqualified for allegedly gaining an advantage by leaving the track and taking a shortcut to rejoin the pit lane after a red flag was displayed. The Race Direction and FIM Stewards upheld the disqualification, prompting Mahias to appeal to CAS. The central legal issue was whether the decision fell under the "field of play" doctrine, which typically limits judicial review of in-competition decisions to preserve the integrity of sports competitions. The CAS panel, led by Sole Arbitrator Michele Bernasconi, acknowledged that while field-of-play decisions are usually unreviewable, exceptions exist for cases involving bad faith or corruption. The panel also noted that post-competition sanctions might not qualify as field-of-play decisions and could be subject to review.
Mahias argued that the FIM Stewards misapplied the regulations, particularly Article 1.21, which governs rider behavior during practice and races. He contended that the race had officially ended with the red flag, making Article 1.21 inapplicable. Instead, he claimed Article 1.26, which addresses race interruptions, should have been the basis for adjudication. Mahias also argued that Article 1.21.3 was non-binding due to its use of the term "should," indicating a recommendation rather than a strict obligation. He further asserted that the sanction was disproportionate, given mitigating circumstances like the lack of clear regulations on pit lane entry and his good faith actions for safety reasons.
The FIM defended the Stewards' decision, arguing that it was a non-reviewable field-of-play decision unless arbitrariness or bad faith was proven, which it claimed was absent. The FIM maintained that the Race Direction's authority under Article 1.6.5 covered on-track incidents, justifying the disqualification. The FIM also sought cost contributions from Mahias for the proceedings.
The Sole Arbitrator examined whether Mahias was "actively competing" when the red flag was displayed, concluding that the FIM Regulations lacked a precise definition of this term. The official race document indicated Mahias had a technical problem, not that he was "out," supporting the view that he was still an active participant. The Arbitrator also determined that Article 1.21 could apply post-red flag in some contexts but found that Article 1.21.3, which prohibits gaining an advantage by deviating from the track, did not apply after the race was halted. However, the Arbitrator ruled that Mahias violated Article 1.21.18 by entering an unofficial pit lane section marked with cones, warranting a fine of EUR 1,000 for disregarding officials' signals.
Ultimately, the CAS partially upheld Mahias's appeal, ordering his inclusion in the final race ranking as the winner with 25 championship points while imposing the fine. The decision highlighted the need for clearer definitions in the FIM Regulations to avoid future ambiguities and underscored the balance between respecting sporting autonomy and ensuring fair adjudication. The case illustrates the complexities of applying legal principles to sports disputes while maintaining procedural integrity and fairness.