The case involves Brazilian marathon runner Vanderlei de Lima and the Brazilian Olympic Committee (BOC) appealing against the International Association of Athletics Federations (IAAF) following an incident during the 2004 Athens Olympic Games marathon. While leading the race, de Lima was attacked by a spectator who pushed him off the course, causing a disruption that lasted 15 to 20 seconds. Despite recovering, he was overtaken by other runners and finished third, earning a bronze medal. The Brazilian delegation appealed, requesting a gold medal for de Lima without altering the official results, but the IAAF upheld the outcome, citing the inability to change final results while expressing sympathy for the incident.
The appeal to the Court of Arbitration for Sport (CAS) argued that the attack caused de Lima to lose time and momentum, impacting his performance. His team presented calculations suggesting he would have won without the interference and highlighted psychological and physiological effects. They also criticized race organizers for inadequate security, citing violations of IAAF rules. The IAAF countered that the CAS lacked authority to alter results, emphasizing field-of-play decisions are final unless evidence of arbitrariness or bad faith exists. The CAS panel agreed, stating its role was not to reassess outcomes without proof of official misconduct. It noted that even if the decision had been arbitrary, the remedy would not involve awarding a supplementary medal but potentially invalidating the race. The CAS upheld the IAAF’s decision, concluding no evidence justified overturning the results.
The case underscored the principle that judges should not interfere with in-competition decisions absent clear procedural violations or bias. De Lima was praised for his sportsmanship, receiving an honorary Pierre de Coubertin medal. The ruling reinforced the limited scope of CAS review in field-of-play matters, emphasizing finality in athletic competition outcomes unless exceptional circumstances are proven. The CAS addressed jurisdictional issues, noting the appeal was filed late but proceeded with IAAF consent. It confirmed de Lima’s standing as an appellant but dismissed the BOC’s formal standing. The applicable law was determined to be IAAF rules.
On the merits, the CAS examined its review authority, acknowledging jurisdiction but deferring to sports bodies' final decisions unless arbitrariness or bad faith is proven. It found no such evidence in the IAAF Jury of Appeal’s decision, which relied on video and finishing times. The CAS dismissed the appeal, affirming the race outcome. The decision highlights the high threshold for overturning field-of-play decisions and the importance of finality in sports adjudication. The ruling reaffirms that such decisions are generally final unless tainted by clear misconduct. The panel expressed sympathy for de Lima but concluded no legal remedy was available, recognizing his sportsmanship and dignity.