Do US courts have jurisdiction over international sports federations in match-fixing cases?

In a series of decisions with potential jurisdictional implications for international sports federations, U.S. federal courts in New York have rejected former Nigerian national team coach Samson Siasia’s attempts to overturn his five-year FIFA ban for match-fixing.

Siasia, a U.S. citizen, received a lifetime ban in 2019 after he was implicated in the extensive match-fixing schemes orchestrated by convicted Singaporean match-fixer Wilson Raj Perumal. Siasia has since challenged the ban in multiple settings, including before FIFA and the Court of Arbitration in Sport, and most recently, in a civil rights suit against FIFA in New York federal court.

Siasia filed the civil rights suit in 2021, alleging violations of his U.S. constitutional rights to due process under the Fifth (protects criminal defendants from having to testify if they may incriminate themselves through the testimony) and Fourteenth Amendments (addresses citizenship rights and equal protection under the law), an unlawful taking under the Fifth and Fourteenth Amendments, and cruel and unusual punishment under the Eighth Amendment (Excessive bail shall not be required, nor excessive fines imposed, nor cruel and unusual punishments inflicted), as well as various state law torts. He argued that FIFA exerted governmental functions in conducting its investigation and adjudication for bribery, and that the CAS operated as FIFA’s “private criminal court.”

The U.S. District Court for the Southern District of New York (“SDNY”) and the U.S. Court of Appeals for the Second Circuit (“Second Circuit”) both determined that they lacked jurisdiction to hear the case. In dismissing the case on jurisdictional grounds, the courts did not reach further questions of the recognition and reviewability of FIFA or CAS decisions, or whether the FIFA investigation and decision presented rights violations or torts.

This article discusses the background to the issue and the proceedings before the courts in the United States of America, which may give an insight into how federal courts in New York and elsewhere in the United States may approach jurisdiction over international sports federations.