Medina Spirit and Bob Baffert: A Kentucky Derby Winner Disqualified

Timeline

1. May 1, 2021Medina Spirit finishes first in the Kentucky Derby.
2. May 9, 2021Baffert announces the positive test; Churchill Downs suspends him.
3. May 17, 2021NYRA suspends Baffert from its New York tracks; a federal judge blocks the suspension on July 14.
4. Dec 2021Medina Spirit dies after a workout at Santa Anita; a necropsy finds no illegal drugs.
5. Feb 21, 2022Kentucky stewards disqualify Medina Spirit and suspend Baffert for 90 days with a $7,500 fine.
6. Feb 17, 2023A federal judge dismisses most of Baffert's suit against Churchill Downs; the last claim falls on May 24.
7. 2023Churchill Downs extends its ban through 2024 after Baffert's televised comments.
8. Jan 22, 2024Baffert and the colt's owner drop their appeal of the disqualification.
9. May 2, 2024The Sixth Circuit rejects bettors' suit over the disqualification.
10. Jul 19, 2024Churchill Downs lifts its ban after Baffert accepts responsibility.
11. May 3, 2025Baffert returns to the Kentucky Derby; Citizen Bull finishes 15th of 19.

The ethical issues

• Strict responsibility of trainers for substances in their horses.
• Animal welfare and medication use in racing.
• Private property owners imposing discipline beyond regulators.
• Accepting responsibility and its role in sanctions.
• Integrity of the sport's most prominent race.

Stakeholders

Stakeholder	Interests & obligations
The trainer	His career, reputation and ability to compete.
Horse owners	Their horses' eligibility and results.
The horses	Welfare and safety.
Churchill Downs	The integrity and reputation of the Derby.
The Kentucky Horse Racing Commission	Enforcing racing rules.
Bettors and fans	Fair results.

The case

On May 1, 2021, Medina Spirit, trained by Hall of Famer Bob Baffert, crossed the finish line first in the Kentucky Derby.^[1][3] It would have been Baffert’s seventh Derby win.^[3] On May 9, Baffert held a news conference at his barn to announce that the colt had tested positive for betamethasone.^[3]

Background

Betamethasone is a regulated corticosteroid. It was legal in Kentucky for treatment, but the Kentucky Horse Racing Commission’s (KHRC) rules banned its presence in a horse’s system at race time.^[2][3] Another Baffert horse, Gamine, had finished third in the 2020 Kentucky Oaks, run eight months before the 2021 Derby, and was disqualified less than two months before the Derby after testing positive for the same drug.^[2][12]

Baffert and his lawyers said Medina Spirit had been treated with an ointment containing betamethasone to clear up a rash. They argued that the rules regulating the drug applied only to injections into joints, used to reduce swelling.^[2] Baffert also said the ointment was applied in line with the KHRC’s standards so that it would clear the colt’s system before race day, and that he had informed the commission of the treatment.^[3]

In December 2021, Medina Spirit died suddenly after a workout at Santa Anita Park. A necropsy found no evidence of illegal drugs and said the death was likely due to a cardiac event.^[2]

The rules and governance

On February 14, 2022, Baffert and the colt’s owner, Zedan Racing, appeared with counsel before the KHRC’s Board of Stewards.^[1] On February 21, the stewards found violations, suspended Baffert for 90 days, fined him $7,500 and disqualified Medina Spirit from the Derby.^[1] The two rulings were numbered 22-0009 (Baffert’s suspension and fine) and 22-0010 (the disqualification), and the commission noted that both parties had been “afforded due process, as is required by law.”^[1] The same day, Churchill Downs recognized the runner-up, Mandaloun, as the winner of the 147th Kentucky Derby and congratulated its owner-breeder Juddmonte, trainer Brad Cox and jockey Florent Geroux.^[6] The company said it would celebrate the horse “on a future date in a way that is fitting of this rare distinction.”^[6] The KHRC ruled that the route of administration had no bearing on whether the positive was a violation.^[2] The commission upheld the stewards’ decision on appeal, and Baffert pursued the case in a Kentucky circuit court.^[2] He served the 90-day suspension in spring 2022.^[2]

Churchill Downs Inc. (CDI), the private company that owns Churchill Downs and other tracks, acted separately. It suspended Baffert on May 9, 2021, and later set a two-year ban from its tracks through the 2023 Derby.^[2][3] A federal judge upheld CDI’s right to impose the ban.^[2]

In 2023, during the national broadcast of the Belmont Stakes, Baffert said he “wouldn’t have done anything different” because “everything we were doing was legal. We didn’t break any rules.”^[2] CDI extended the ban through 2024, citing “continued concerns regarding the threat to the safety and integrity of racing.” It said: “A trainer who is unwilling to accept responsibility for multiple drug test failures in our highest-profile races cannot be trusted to avoid future misconduct.”^[2] CDI also said Baffert “continues to peddle a false narrative.”^[3]

Can a track shut out a trainer?

Medina Spirit’s positive test led to private tracks excluding Baffert, and to litigation over whether they could do so without a hearing. On May 17, 2021, the New York Racing Association (NYRA) suspended him indefinitely from Belmont Park, Saratoga and Aqueduct. Its letter gave three reasons: Churchill Downs’ suspension, four drug-testing violations in the past year, and Baffert’s “differing explanations” for the positive test. It cited no statute or regulation, only “the best interests of thoroughbred racing,” and gave no end date.^[9] Baffert sued in federal court in Brooklyn. On July 14, 2021, Judge Carol Bagley Amon blocked the suspension. NYRA had previously conceded that it was a state actor, she found. It had suspended Baffert without notice, without a pre-suspension hearing and without offering a prompt hearing afterward, so he was likely to show a violation of due process. At a hearing, she wrote, Baffert “would have the opportunity to present his version of the events.”^[9] The Belmont Stakes had already been run without him.^[9]

Baffert’s suit against Churchill Downs in Louisville went differently. On June 2, 2021, the day a second laboratory test was reported positive, CDI suspended him for two years.^[9] On February 17, 2023, Judge Rebecca Grady Jennings of the Western District of Kentucky dismissed his antitrust claims for lack of an antitrust injury. She also dismissed his tortious-interference claims because CDI had “exercised legitimate contract rights,” and denied a preliminary injunction. She let one claim proceed: that CDI, allegedly entwined with the state, had violated due process with respect to his Kentucky trainer’s license.^[10] On May 24, 2023, she granted CDI summary judgment on that claim too. The license, she wrote, was “not valueless,” since Baffert had used it “to win over $1 million racing horses in the Commonwealth” at Keeneland during the ban. Without a lost property interest there could be no due process violation.^[11]

The bettors

The disqualification also raised a question for bettors. When the stewards placed Mandaloun first in February 2022, their ruling stated: “Pari-mutuel wagering is not affected by this ruling.” Churchill Downs had already paid out on the original order of finish, as Kentucky regulations required.^[12] Nineteen bettors whose wagers would have won under the new order sued CDI and Baffert in a putative class action. They claimed “unpaid winning wagers.”^[12] The federal district court dismissed the case. On May 2, 2024, the Sixth Circuit affirmed: “under Kentucky law governing pari-mutuel wagering, the first official order of finish is final,” so the plaintiffs had lost their bets and suffered no legally recognized harm.^[12] The opinion explained why betamethasone matters. It is allowed for therapeutic purposes, but it “can act as a performance-enhancing drug and can mask lameness and pain, jeopardizing horse and rider safety,” so its use is limited in the two weeks before a race.^[12]

A national regime

When Medina Spirit ran, medication rules were set state by state, which is why Kentucky’s rules and its stewards decided the case.^[1] That changed after the case. The Horseracing Integrity and Safety Authority’s Anti-Doping and Medication Control Program, approved by the Federal Trade Commission, took effect on March 27, 2023. A federal court paused it on March 31 for a procedural waiting period, and the FTC ordered it to resume on May 22, 2023.^[4] Enforcement passed to an independent agency, the Horseracing Integrity & Welfare Unit (HIWU), which oversees test selection nationwide using “an intelligence-based strategy.”^[5]

The national rules draw the distinction at the heart of the Medina Spirit case. “Banned Substances” may not be used or possessed at any time. “Controlled Medications” may be used, “except in close proximity to a race or Vets’ List workout,” and certain controlled medications, including corticosteroids such as betamethasone, are also regulated in samples taken after routine timed workouts.^[5] Under the uniform list, a single standard applies to every covered horse, whatever the state.^[5]

Aftermath

In January 2024, Baffert and Zedan Racing dropped their appeal of the disqualification, ending more than two and a half years of legal proceedings.^[2] Baffert thanked the KHRC and Churchill Downs and said he was “grateful for the changes and the clarity” brought by the Horseracing Integrity and Safety Authority, a national regulator whose drug-enforcement rules took effect in 2023.^[2]

On July 19, 2024, CDI rescinded its ban.^[3] Baffert issued a statement: “I accept responsibility for Medina Spirit’s positive test in the 2021 Kentucky Derby. I am responsible for any substance found in the horses that I train, and I have paid a very steep price.”^[3] CDI’s chief executive said the company was “satisfied that Mr. Baffert has taken responsibility for his actions, completed a substantial penalty and is committed to running in full compliance.”^[3]

Baffert returned to the Derby on May 3, 2025, after a three-year absence. He entered two horses, but Rodriguez was withdrawn days before the race with a bruised foot.^[8] His remaining runner, Citizen Bull, broke from the No. 1 post, set the early pace as Baffert had said he must, and faded to finish 15th of 19 behind Sovereignty.^[7][8]

The core dilemma

Baffert argued he had followed the rules as he understood them, with a legal medication given for treatment. Regulators held that the drug’s presence on race day was a violation regardless. A private company then imposed a longer ban, tied partly to his refusal to accept responsibility. How should racing sanction medication violations, and who should impose them?

Competing values

• Strict responsibility vs. intent: trainers’ accountability for any substance against the circumstances of treatment.
• Public regulation vs. private power: the commission’s sanction against the track owner’s own ban.
• Contrition vs. consistency: whether accepting responsibility should change outcomes.
• Animal welfare vs. competition.

Strongest arguments

For the sanctions: the rule banned the drug’s presence at race time, and trainers are responsible for what is in their horses. A repeat violation in a high-profile race justified strong action. CDI has a right to protect its event.

Against or for limiting them: the drug was legal, given for treatment, and disclosed. CDI’s three-year ban far exceeded the regulator’s 90 days and was tied to speech, raising concerns about private power.

For a middle view: strict responsibility is necessary, but sanctions beyond regulators’ should follow clear, published standards.

Applying the frameworks

Justice

A justice lens asks whether the 90-day suspension and the three-year CDI ban were proportionate and consistent, and whether a private company should impose sanctions beyond the regulator’s.

Virtue ethics

A virtue lens examines accountability: Baffert’s initial insistence that he did nothing wrong and his later acceptance of responsibility, and CDI’s emphasis on contrition.

Care ethics

A care lens focuses on horse welfare and asks whether medication rules adequately protect the horses that bear the risks of racing.

Walk it through: the Simple Decision Model

1. Spot the issue. You are CDI’s chief executive deciding whether to ban the trainer. Stakeholders include trainers, owners, horses, bettors and fans. Less visible are owners whose horses would be excluded. The codes are state racing rules and your track policies.
2. Gather facts. What did the test show? What is the trainer’s history? What did regulators decide? Beware letting public pressure drive the decision.
3. Test options. (a) Rely on the regulator’s sanction. (b) Impose your own ban. (c) Impose a ban with clear conditions for reinstatement.
4. Check codes and law. Check your legal rights as a private track and any state rules.
5. Decide and document. Explain the basis for the ban and how it can end.
6. Communicate and follow up. Publish the decision and review it as circumstances change.

What’s settled and what’s contested

• Settled: the positive test; the disqualification; the 90-day suspension; CDI’s ban and its rescission; Baffert’s acceptance of responsibility in 2024.
• Contested: whether the ointment should have been treated differently; whether CDI’s ban was proportionate.

Why this case matters

The Medina Spirit case shows how strict responsibility works in racing, and how private venue owners can wield disciplinary power beyond regulators. It is a case study in accountability, contrition and governance.

See also: Federal Drug Rules for Racehorses: HISA’s Medication Program on Trial.

Key terms

Strict liability

The anti-doping principle that athletes are responsible for any prohibited substance in their bodies, whether or not they meant to take it.

Due process

Fair procedures before a sanction: notice, a chance to respond, an impartial decision-maker and a right of appeal.

Integrity

A commitment to honesty and ethical principle in competition and administration, including when nobody is watching.

Institutional accountability

Structures that make a sport organization explain its decisions and face consequences: clear authority, transparency, appeals, independent oversight and enforcement.

Trust

The public’s belief that what they are watching is real. Integrity failures are ultimately failures of trust.

Non-maleficence

The duty to avoid causing harm, often paired with care ethics when setting safety rules.

Definitions from the Ethics Cases glossary.

Discussion questions

1. Baffert argued that betamethasone was given in an ointment, not an injection, and that the rule applied only to injections. Should the route of administration matter?
2. Churchill Downs banned Baffert for longer than regulators did, citing his refusal to accept responsibility. Is it fair for a private track to impose its own sanctions?
3. Churchill extended the ban after Baffert said he 'wouldn't have done anything different.' Should a person's statements affect the length of a sanction?
4. How should racing balance legitimate veterinary treatment against race-day medication rules?

Sources

1. KHRC's Board of Stewards issues rulings (21 February 2022) — Kentucky Horse Racing Commission
2. Baffert, Zedan drop appeal in Medina Spirit case — Daily Racing Form
3. Bob Baffert's 3-year suspension is lifted by Churchill Downs — Horse Racing Nation
4. FTC orders HISA to resume Anti-Doping and Medication Control Program May 22 (Apr. 27, 2023) — Horseracing Integrity and Safety Authority
5. HISA Anti-Doping and Medication Control Program to relaunch May 22, 2023, under enforcement of HIWU — Horseracing Integrity & Welfare Unit
6. Churchill Downs' Statement in Response to KHRC Stewards Ruling on Kentucky Derby 147 (Feb. 21, 2022) — Churchill Downs Incorporated
7. Sovereignty edges Journalism to win 151st Kentucky Derby at rain-soaked Churchill Downs (May 3, 2025) — NBC Sports
8. Sovereignty wins the 151st Kentucky Derby (May 3, 2025) — CNN
9. Baffert v. New York Racing Association, No. 21-CV-3329 (CBA), Memorandum & Order (E.D.N.Y. July 14, 2021) — U.S. District Court for the Eastern District of New York (via Courthouse News Service)
10. Baffert v. Churchill Downs, Inc., No. 3:22-cv-123-RGJ, Memorandum Opinion and Order (W.D. Ky. Feb. 17, 2023) — U.S. District Court for the Western District of Kentucky (via WHAS11)
11. Judge Dismisses Baffert's Lone Remaining Claim Against CDI (May 24, 2023) — Thoroughbred Daily News
12. Mattera v. Baffert, No. 23-5750 (6th Cir. May 2, 2024) — U.S. Court of Appeals for the Sixth Circuit (via CourtListener)