Imogen Simmonds: Anti-doping regulation, enforcement, and the defence of intimate contact
Published on June 11, 2025 by Charles Harrison and Joel Cain
Professional triathlete, and 4th place finisher at the 2024 70.3 Ironman World Championship, Imogen Simmonds (Simmonds), tested positive in December 2024 (made public in February 2025)[1] to a banned substance during an out-of-competition test conducted by the International Testing Agency (ITA) on behalf of Ironman. According to the February press release, metabolites of Ligandrol (the banned substance) were found in Ms Simmonds’ sample [2].
In statement from the ITA regarding the Simmonds case, “In accordance with the World Anti-Doping Code and Article 7.4.1 of the IRONMAN Anti-Doping Rules, the athlete is under provisional suspension. The athlete has the right to challenge the provisional suspension and ask for its lifting” [3].
Ms Simmonds released her own statement via Instagram, claiming that she had been exposed to the banned substance through intimate contact with her partner, who had been taking the substance without Ms Simmonds knowledge. Ms Simmonds claims that the amount found in her urine sample was equivalent to “a dash of salt in an Olympic swimming pool”, with private hair testing of her and her partner confirming this. This testing has not been acknowledged by ITA [4].
What is Ligandrol
Ligandrol is a Selective Androgen Receptor Modulator (SARM) that has been studied as a treatment for conditions such as cancer where patients experience muscle weakness and wastage. SARMs can help repair and build muscles but are not yet approved by the Australian Therapeutic Goods Administration (TGA). These substances have become popular (or notorious) in bodybuilding circles as a ‘safe’ alternative to synthetic testosterone and anabolic steroids.
SARMs are prohibited by the World Anti Doping Agency (WADA) for all competitive athletes at all times due to their anabolic qualities and ability to stimulate bone and muscle growth. They are not without their own side-effects and long-term effects are unknown.
The ‘defence’ of intimate contact
Whilst intimate contact is not itself a defence against a positive doping test, Article 10.5 of the WADA code allows an athlete to have a period of ineligibility resulting from a positive test to be struck out should they prove no fault or negligence [5]. Ms Simmonds is not the first athlete to claim exposure to prohibited substances via intimate contact and is planning to challenge her suspension from triathlon.
On 14 January 2025, the Court of Arbitration for Sport (CAS) handed down its ruling in an analogous case, 2024/ADD/95 World Curling v. Briane Harris (The Ruling). In this case, a curling player claimed to have come into contact with Ligandrol through intimate contact with her husband, a non-competitive gym-goer who was taking a supplement which contained the banned substance.
Briane Harris (the Athlete) and her husband provided hair samples to an expert, the analysis of which confirmed that only the husband had taken the banned substance [6]. The Athlete also submitted that she did not know or suspect that her husband had been taking the supplement, nor was she aware of a risk of contamination from intimate contact, citing the relevant anti-doping program by the Canadian Centre for Ethics in Sport and noting the lack of any warning suggesting that prohibited substance could be transferred via bodily fluids [7].
World Curling argued to the contrary, claiming that the Applicant’s husband ought to know of the restrictions which the Athlete is subject to as an international athlete, and must also exercise caution [8]. World Curling argued further that it was implausible that the Athlete did not know of her husband’s substance use, noting that he admitted to ceasing consumption of the supplement due to undesirable side effects, including acne [9] World Curling also submitted that the additional hair testing did not meet the relevant standards required in doping procedures and lacked a proper chain of custody and therefore was inadmissible.
The decision
CAS was satisfied that the evidence presented supported the conclusion that intimate contact was the source of the prohibited substance in the Athlete’s body,[10] noting the trace amounts of the substance in the Applicant’s urine sample, the husband’s testimony and expert evidence regarding Ligandrol and its capacity to remain detectable after a single exchange of bodily fluids.
CAS did observe that the hair testing did not meet the same standards as the urine testing, however, stated that it was useful as it narrowed the potential sources of the substance. CAS gave minimal weight to this element of evidence, though was mindful that the Athlete had limited means of defence to the accusations laid before them [11].
Consequences and considerations
The rise of such cases in the sporting world reveals a significant oversight in current anti-doping protocols. It is a problem that potentially cannot be solved via further athlete regulation. CAS conscientiously elected not to impose standards of communication between spouses in its decision, as doing so would be akin to adjudicating the dynamics of intimate and personal relationships. CAS deemed this to be outside of its jurisdiction, and may likely amount to overreach should anti-doping or other governing bodies attempt to intervene. CAS noted further that the Athlete’s husband was not an international athlete and could not be bound by anti-doping regulations [12].
Changes to testing protocols, particularly in circumstances involving trace amounts of prohibited substances, may aid the situation. Hybrid testing, involving for example, urine and hair samples, may be useful in distinguishing between a ‘true’ positive test and one that is the result of contamination.
The Sole Arbitrator gave consideration to the lack of educational material warning athletes of the risks of intimate contact. In the absence of changes to regulations or testing protocols, it may be these institutions that provide such education that bear the burden of responsibility to ensure that athletes are fully equipped to avoid the potentially career-ending situation that Ms Simmonds currently finds herself in.
Integrity issues in professional, and indeed amateur, sports – such as allegations of doping – remain an issue of ongoing close consideration – as they should. The case of Simmonds’ and Harris’, the latter outlined in the Ruling, confirm the ongoing complex challenge of balancing the need for integrity in sports and having identification-enforcement mechanisms which work versus the practical realities of athletes and whether innocuous/unidentifiable non-compliance with anti-doping protocols – if so, how and to what extent.
The impact of the Ruling on the Simmonds’ case will inevitably play out into the future. We will keep you updated as to all developments as they arise.
Please note that this article does not constitute legal advice. If you are seeking professional advice on any legal matters, you can contact Carroll & O’Dea Lawyers on 1800 059 278 or via our Contact Page and one of our lawyers will be able to assist you.
[1] https://www.tri247.com/triathlon-news/elite/imogen-simmonds-reveals-positive-drug-test-ligandrol
[3] Ibid.
[4] https://www.instagram.com/p/DGiRzViIsvV/?hl=en
[5] World Anti-Doping Code, 2021
[6] The Ruling, [51].
[7] The Ruling, [57].
[8] The Ruling, [41].
[9] The Ruling, [41].
[10] The Ruling, [83].
[11] The Ruling, [82].
[12] The Ruling, [83].
