Reynolds v. International Amateur Athletic Federation

After Reynolds (plaintiff) obtained a default judgment and a $27.3 million award against the IAAF (defendant) in Ohio federal court -- based on a finding that the IAAF's American member, the TAC, had sufficient Ohio contacts to serve as its agent -- Reynolds tried to garnish money owed to the IAAF by U.S. sponsors. The IAAF, a London-based unincorporated association of 205 national federations with no U.S. offices and no events held in Ohio, appeared to quash the garnishment and vacate the judgment for lack of personal jurisdiction; the district court denied the motion, and the IAAF appealed.