Ethics CasesSport

Cases · CBF (Brazil) · 2017–2025

Courts and the Brazilian Football Confederation Presidency

Brazil's football confederation (CBF) has faced years of litigation over its election rules. A 2017 lawsuit by Rio de Janeiro prosecutors challenged changes to the voting system. Ednaldo Rodrigues, who became interim president in 2021 and was elected in 2022, was removed by a Rio court in December 2023, reinstated by a Supreme Court justice a month later, and re-elected unopposed in March 2025. In May 2025, a Rio appellate judge annulled the settlement that had ended the litigation, citing a signatory's lack of capacity and a possibly forged signature, and removed Rodrigues. The CBF's assembly accepted the ruling, and Samir Xaud was elected as the sole candidate amid a boycott by many clubs. The case asks how courts, governments and international bodies should balance sport's autonomy against legal accountability.

By Tanner Simkins, editor

Timeline

  1. Rio de Janeiro prosecutors file a civil action challenging the CBF's election rules.
  2. Rodrigues becomes interim CBF president after his predecessor is removed.
  3. Rodrigues is elected president, the sole candidate, after a settlement with prosecutors.
  4. The Rio court invalidates the settlement and removes Rodrigues, appointing an intervener.
  5. FIFA and CONMEBOL warn that third-party interference could lead to Brazil's suspension.
  6. Supreme Court justice Gilmar Mendes reinstates Rodrigues, citing the Olympic qualifying deadline.
  7. A new settlement signed by five officials ends the case; Rodrigues is re-elected early, unopposed.
  8. A Rio appellate judge annuls the settlement and removes Rodrigues, naming an interim administrator.
  9. After Rodrigues drops his challenge, the Supreme Court archives his petition to return.
  10. Samir Xaud is elected CBF president for 2025–2029; 18 clubs boycott the vote.
  11. Infantino meets Xaud and congratulates him on his election.

The ethical issues

  • Sport's autonomy versus legal accountability.
  • Integrity of governance agreements and signatures.
  • Weighted voting and club representation.
  • Stability of national federations amid litigation.
  • Uncontested elections and legitimacy.

Stakeholders

StakeholderInterests & obligations
The CBF and its officersStable, legitimate governance.
State federationsTheir weighted voting power.
ClubsRepresentation in the CBF.
Courts and prosecutorsUpholding the law.
FIFA and CONMEBOLFederation autonomy and stability.
Players, coaches and fansA functioning national team program.

The case

On May 15, 2025, an appellate judge of Rio de Janeiro’s state court removed Ednaldo Rodrigues as president of the Brazilian Football Confederation (CBF), the governing body of Brazil’s most famous sport.[1] It was the second time the court had removed him.[1] Behind the ruling lay an eight-year legal fight over who writes the CBF’s election rules, and a recurring collision between Brazilian courts and FIFA’s insistence that national federations run their own affairs.

Background

The dispute began in 2017, when Rio de Janeiro state prosecutors sued over changes to the CBF’s election rules.[1] Rodrigues, a former head of the Bahia federation, became CBF vice-president in 2018 and interim president in 2021 after the previous president was removed.[1] In March 2022, after the CBF reached a settlement with prosecutors (a termo de ajustamento de conduta, or TAC) that changed the election rules, he was elected the sole candidate, with 137 of 141 votes.[1][5]

A new lawsuit challenged that settlement. In December 2023, the Rio court held that the prosecutors had lacked standing to intervene, annulled the TAC, removed Rodrigues and appointed an intervener to run the CBF.[1][5]

The rules and governance

Brazilian law. Brazil’s Constitution directs the state to promote sport while respecting “the autonomy of sports governing entities and associations as to their organization and functioning.”[6]

FIFA’s statutes. On December 24, 2023, FIFA and CONMEBOL wrote to the CBF that under articles 14 and 19 of the FIFA Statutes, member associations “must manage their affairs independently and without undue influence from any kind of third parties.” A breach could lead to suspension “even if the third-party influence was/is not the fault of the member association.” They warned that no elections should be held before a joint mission to Brazil in January 2024. A suspension would bar Brazil’s national and club teams from all international competition.[4]

The weighted vote. The CBF’s electoral college gives state federations three points each, Serie A clubs two and Serie B clubs one. The weighting was part of the rule changes the prosecutors challenged.[3]

The 2024 reinstatement

On January 4, 2024, Supreme Court justice Gilmar Mendes suspended the Rio ruling and restored Rodrigues and the board elected in 2022. Ruling in a constitutional challenge brought by a political party, he held that because sport has “relevant social interest,” prosecutors could in principle intervene in sports bodies’ affairs. He also found that the removal risked “serious and irreparable harm,” because FIFA did not recognize the court-appointed intervener. Without a recognized signatory, Brazil could not enter the Paris 2024 Olympic qualifying tournament, whose registration deadline was the next day.[5]

In January 2025, a new agreement signed by five officials ended the case, and in February the Supreme Court recognized the 2022 election. In March, Rodrigues brought the election forward and was re-elected unopposed.[1]

The 2025 removal

In April 2025, a federal legislator asked the Supreme Court to remove Rodrigues. He disputed the authenticity of the signature of former CBF president Antônio Carlos Nunes de Lima on the January agreement. Justice Mendes rejected the request, saying it was for the Rio courts.[1] On May 15, Judge Gabriel de Oliveira Zéfiro annulled the agreement, citing the signatory’s “mental incapacity” and “possible forgery” of his signature. He named vice-president Fernando Sarney as interim administrator to call new elections.[1]

Rodrigues first tried to return through the Supreme Court. Justice Mendes had asked the parties, the Attorney General’s office and the Prosecutor General to respond to his request. Rodrigues then told the court he was withdrawing his challenge to the Rio ruling, and on May 20 Mendes archived the petition (Pet 13783) and cancelled that order.[7]

Aftermath

This time the CBF itself moved quickly. On May 24, a CBF extraordinary assembly attended by 26 of 27 state federations declared the court ruling compatible with the CBF statute and with FIFA and CONMEBOL autonomy principles. It declared the 2022 and 2024 statute reforms and the 2022 and 2025 elections legally void and validated a new election. It said FIFA and CONMEBOL had been informed and invited to observe.[2]

On May 25, Samir Xaud, a 41-year-old physician who led the Roraima federation, was elected the sole candidate for 2025–2029 with 103 of a possible 141 points. Twenty-five federations and ten of 40 Serie A and B clubs voted for him; 18 clubs boycotted the vote.[3] The election came a day before Carlo Ancelotti named his first Brazil squad.[3] In 2023 FIFA had threatened suspension to stop a court-driven election. In 2025 the confederation’s own assembly adopted the court’s result and invited FIFA to watch.[2][4]

The governance questions behind the vote stayed open. Before the election, the trade outlet Máquina do Esporte reported that the May 24 assembly, called by the interim administrator, would revoke statute changes adopted under Rodrigues in late 2024. Those changes had made intervention in member federations the president’s sole prerogative, where it had previously required the board’s approval. They had also removed the board’s power to expel people who violated the statute and dropped a rule barring contracts with companies owned by officials’ relatives.[8] Under the statute, only the 27 state federations take part in such administrative assemblies, and the clubs were not invited.[8] The 21 Serie A and B clubs that announced a boycott said they disagreed with the “processo vigente” (the current process, in translation). Through the Liga Forte União, they demanded more weight in elections, a place in all general assemblies, a commitment to a unified league, and recognition that the commercial rights of Series A and B belonged to the clubs.[8] Xaud became the sole candidate after the president of the São Paulo federation failed to gather the eight federation endorsements needed to register, despite support from 32 club presidents.[8]

FIFA accepted the result. UOL reported, in an account carried by Folha BV, that FIFA secretary general Mattias Grafström sent Xaud a letter congratulating him on his victory.[10] In June 2025, FIFA published an account of a meeting in Miami at which Gianni Infantino “congratulated him on his recent election” and thanked the CBF for its “exemplary work and collaboration with FIFA.” Xaud said they had discussed “all the changes that we need to make in Brazilian football to align it with the global game.”[9]

The core dilemma

Courts acted on allegations of a defective governance agreement, and the CBF’s own assembly accepted the result. But repeated judicial intervention destabilized the federation, and international bodies prize sport’s autonomy. When is court intervention in sports governance justified?

Competing values

  • Rule of law vs. sport’s autonomy.
  • Stability vs. legitimacy.
  • Federation power vs. club representation.
  • Speed vs. due process in resolving disputes.

Strongest arguments

For judicial intervention: a governance agreement with a questioned signature cannot stand. National law applies to national federations.

Against frequent intervention: repeated removals and reinstatements disrupt the national team and invite international concern. Disputes should be resolved through internal processes where possible.

On the election: a sole-candidate election with a large club boycott raises legitimacy questions, even if lawful.

Applying the frameworks

Justice

A justice lens asks whether the voting system fairly represents federations and clubs, and whether the court processes were fair.

Virtue ethics

A virtue lens examines the honesty and integrity of leaders in creating governance agreements.

Utilitarianism

A utilitarian lens weighs the costs of instability against the benefits of enforcing legal standards.

Walk it through: the Simple Decision Model

  1. Spot the issue. You are a federation delegate after the court ruling. Stakeholders include clubs, federations, players and fans. Less visible are international bodies. The codes are the CBF statute, national law and FIFA rules.
  2. Gather facts. What did the court find and what does the statute require? Beware choosing sides by political alliance.
  3. Test options. (a) Accept the ruling and hold elections. (b) Appeal and keep current leadership. (c) Reform voting rules before elections.
  4. Check codes and law. Check the statute and FIFA autonomy principles.
  5. Decide and document. Record reasons.
  6. Communicate and follow up. Invite observers and publish results.

What’s settled and what’s contested

  • Settled: the May 2025 ruling, the assembly’s decisions and the election result.
  • Contested: the fairness of weighted voting; the legitimacy of uncontested elections; the right balance between courts and autonomy.

Why this case matters

The CBF saga shows how weak internal governance invites outside intervention, and how courts, federations and international bodies interact.

Key terms

Institutional accountability
Structures that make a sport organization explain its decisions and face consequences: clear authority, transparency, appeals, independent oversight and enforcement.
Stakeholders
Everyone with something at stake in a decision: athletes, coaches, parents, officials, fans, employees, sponsors, media, communities and regulators, including the less visible ones.
Trust
The public’s belief that what they are watching is real. Integrity failures are ultimately failures of trust.
Due process
Fair procedures before a sanction: notice, a chance to respond, an impartial decision-maker and a right of appeal.
Consent and autonomy
Whether people have agreed freely and with full information, and whether their right to make their own choices is respected.

Definitions from the Ethics Cases glossary.

Discussion questions

  1. When should courts intervene in a sports federation's elections?
  2. Federations had triple-weighted votes, Serie A clubs double and Serie B clubs single. Is that fair?
  3. Many clubs boycotted the 2025 election. How should a sole-candidate election be judged?
  4. How should FIFA's autonomy principles apply when national courts act on governance disputes?

Sources

  1. A acusação de fraude que derrubou presidente da CBF — BBC News Brasil
  2. Assembleia Geral Extraordinária da CBF reconhece legitimidade da eleição deste domingo — Confederação Brasileira de Futebol
  3. Candidato único, Samir Xaud é eleito presidente da CBF — Agência Brasil
  4. Letter from FIFA and CONMEBOL to the CBF, 'Situation of CBF' (Dec. 24, 2023) — FIFA / CONMEBOL (published by Poder360)
  5. STF determina retorno de Ednaldo Rodrigues à presidência da CBF (Jan. 4, 2024) — Supremo Tribunal Federal
  6. Constituição da República Federativa do Brasil de 1988, art. 217 — Presidência da República (Planalto)
  7. STF arquiva pedido de Ednaldo Rodrigues para retornar à presidência da CBF (May 20, 2025) — Supremo Tribunal Federal
  8. CBF revogará mudanças feitas por Ednaldo no estatuto, mas demandas de clubes seguem fora da pauta (May 22, 2025) — Máquina do Esporte
  9. FIFA President discusses FIFA Women's World Cup 2027 with Brazilian counterpart (June 21, 2025) — FIFA
  10. Fifa reconhece eleição de Samir Xaud na CBF (May 29, 2025) — Folha BV