By Anna Giambelluca, Esq, Legal Editor
When Russia invaded Ukraine on February 24, 2022, Lesia Tsurenko was in Mexico preparing to play tennis. Within hours, she claims the atmosphere at the tournament shifted: Russian players stopped speaking to their Ukrainian counterparts. Over the next two years, Tsurenko would put pressure on the Women’s Tennis Association to do something about it. What she found, and what a federal court confirmed in March 2026, is that the law offers athletes very little leverage over the organizations they depend on, even when those organizations have clearly failed them.
The Complaint
Tsurenko sued the WTA Tour and its then-CEO Steve Simon in the Southern District of New York, alleging breach of contract, negligent supervision, and negligent infliction of emotional distress. The case rested on two years of specific incidents that were documented and reported, and according to Tsurenko, ignored.
It started with a promise. At a March 2022 meeting in California, Simon allegedly promised that any Russian or Belarusian player who publicly supported the war would be banned from WTA events. It didn’t take long for that promise to be tested. Two months later, at the French Open, Russian athlete Veronika Kudermetova wore a Tatneft sponsorship patch—a company whose subsidiary had been sanctioned by the EU for supplying tires to the Russian army. Tsurenko reported it. Nothing happened. Ukrainian player Marta Kostyuk submitted a written complaint to the WTA after refusing to play a doubles match against two Russian players, one of whose husbands had publicly backed the invasion. The complaint was sent directly to Simon, and was never acknowledged. Later, the French Open tournament director Amelie Mauresmo told a group of Ukrainian players that a planned presentation about the war had been blocked by Simon.
The complaints kept coming, and according to Tsurenko, kept going nowhere. At the 2023 Australian Open, fans sat in the stands wearing Putin t-shirts and waved Russian flags during a match between Ukrainian and Russian players. WTA security did not intervene.
Tsurenko requested a private meeting with Simon to explain the psychological toll the situation was taking on Ukrainian players. His alleged response: “It is OK to support the war. It is another person’s opinion and it should not hurt you.”
Shortly after, an hour before Tsurenko was scheduled to play Belarusian star Aryna Sabalenka, she had a panic attack. She went to her supervisor, visibly distressed, and said she could not go on. Allegedly, the supervisor replied saying that she had to play, or the WTA would lose money. Tsurenko withdrew anyway. On multiple occasions, WTA’s head of security told Tsurenko’s coach to take off the Ukrainian flag he was wearing.
Tsurenko brought all of this evidence to a WTA Board meeting. Within months, a disciplinary case was opened against her coach. She believed it was payback for speaking up. A WTA committee eventually cleared Simon of any misconduct.
Legal Framework
On March 25, 2026, Judge Naomi Reice Buchwald dismissed all of Tsurenko’s claims. The opinion seems to be aware of the gap between what the law can do and what the situation may deserve.
Before getting anywhere near the substance of her claims, Tsurenko ran into problems based on the waivers she had signed. Both the WTA’s Annual Player Form and its By-Laws include language releasing “any and all claims” against WTA arising from decisions, rulings, actions, or inactions within its jurisdiction. Essentially encompassing all of her complaints.
Tsurenko argued that the waivers were unconscionable. Because WTA dominates professional women’s tennis globally, players do not have much practical choice regarding signing these waivers. The court acknowledged the imbalance in bargaining power, but was unmoved. WTA membership comes with real advantages: automatic entry into main draw events, access to higher prize money, professional development programs, and the benefit of being shielded by the same waiver from claims by other players. A player who didn’t want to sign the waiver could still compete on the tour, she would just be doing it at lower-tier events. No one technically forced Tsurenko to sign.
The contract claim also fell apart on its merits. The only WTA rule Tsurenko identified as having been breached was one requiring “Tournament Support Personnel” to avoid conduct detrimental to the tour. However, that is a defined category covering tournament directors, owners, operators, and their agents. The WTA itself does not fall within it, meaning the rule she cited simply didn’t apply to the defendant.
Duty to Protect Players from Geopolitics?
The negligence claim is the most substantive part of the case, and the hardest to dismiss—legally or otherwise.
Tsurenko’s argument was that WTA owed Ukrainian players a duty of care that included their mental and emotional wellbeing. She pointed to federal statutes and New York common law holding that sports organizers must shield participants from “unassumed, concealed, or unreasonably increased risks.” The court did not find this argument compelling. The federal statutes she cited apply to the U.S. Olympic and Paralympic Committee and amateur athletics. Professional tennis sits outside of their reach entirely.
The New York precedents she relied on, including Benitez v. New York City Board of Education (1989) and Morgan v. State (1997), were both about physical injuries. When courts have found that sports bodies owe players a duty, those duties have always been about keeping them physically safe. The emotional toll of competing against players from a country at war with your own is a different category of harm entirely, and one the courts haven’t yet recognized as a legal duty.
Tsurenko also pushed the argument that Simon’s promise in 2022 created an assumed duty: by telling her players who supported the war would be banned, he effectively took on a legal obligation to follow through. Courts do recognize assumed duties in some circumstances, but only when a plaintiff reasonably relied on a defendant’s conduct to her detriment. The court found Tsurenko’s reliance here unreasonable for two reasons. First, what she was asking for, banning players for their political views, would have put WTA in an impossible position. Second, Simon did not have the authority to ban players on his own; that required a Board vote. The Court concluded that relying on a promise from someone without the authority to keep it was unreasonable.
The Deference Doctrine
Underlying every piece of the ruling is a principle the court doesn’t shy away from: judges should stay out of the internal affairs of private sports organizations. The rule is that courts defer to how sports bodies interpret their own rules unless there is a showing of bad faith or illegal conduct. Tsurenko fell short of that bar.
The clearest illustration of where this deference leads is the court’s response to her proposed remedies. Tsurenko argued WTA should have rescheduled matches to keep Russian and Ukrainian players apart, and enforced its rules against national symbols more rigorously. The court pointed out what that would actually require: the court telling an international sports organization which side of a foreign war it should take, restructuring a global event schedule around that determination, and managing fan behavior worldwide. Judge Buchwald wrote that is not a job for the judiciary.
The court also noted that WTA hadn’t been completely passive. The joint statement issued by the major tennis governing bodies in March 2022 (where they allowed Russian and Belarusian players to compete, but not under their national flags) was a real decision. The court deferred to it, even if the players most directly affected found it inadequate.
What the Case Leaves Open
The ruling, while legally sound, does leave some things unaddressed.
The waivers here are exceptionally broad. They don’t just cover injuries from tournament logistics, but rather they cover any “decision, ruling, action, or inaction” by WTA or its officers across “all matters within their respective jurisdictions.” Read literally, that protects the organization from almost any claim a player could bring. The court did not wrestle with whether waivers that wide are really what the law was designed to protect, or whether they’ve essentially become the price of entry to participate in the sport players have spent their entire life pursuing.
There is also nothing in the ruling about whether WTA actually responded adequately to Tsurenko’s complaints. The court concluded that players who signed these waivers can’t sue when the organization handles things badly, not that the organization handled things well.
The Bottom Line
Tsurenko v. WTA Tour is a case about war, sport, and the law’s reluctance to get involved when the two collide. Tsurenko’s allegations, if true, describe an organization that made promises it didn’t keep, dismissed player complaints, pressured an athlete to compete in the middle of a panic attack, and opened a disciplinary case against her coach when it seemed she became too loud about it. The court’s answer wasn’t that none of this happened, but rather that it wasn’t the legal system’s place to deal with it.
For athletes, the lesson is uncomfortable: the broader the waiver you sign, the more you are betting on the organization’s goodwill rather than any legal protection. For sports governing bodies, the case confirms that sweeping liability waivers, signed and re-signed over the years, are remarkably durable—even when the conduct they shield looks bad on paper.
The court’s job was to decide whether Tsurenko had a legal case. It wasn’t to decide whether WTA did the right thing. Those are two separate questions, and only one of them has been answered.
