Arrington v. Louisiana State Racing Comm'n
Louisiana Court of Appeal
482 So.2d 200 (1986)
- Written by Brett Stavin, JD
Facts
Bobby Arrington (defendant) was a racehorse owner and trainer licensed under Louisiana law. On March 3, 1983, a racehorse belonging to Arrington finished second in a race at Evangeline Downs, making the horse eligible to share in the purse for that race. After the race, an analysis of the horse’s urine indicated the presence of methamphetamine. Arrington requested a second test be performed, and the second test likewise proved positive. The board of stewards at Evangeline Downs suspended Arrington’s racing privileges. On appeal to the Louisiana State Racing Commission (the commission) (plaintiff), the commission suspended Arrington’s owner and trainer license for 18 months and imposed a $500 fine. After a rehearing as ordered by the Orleans Parish Civil District Court, the commission affirmed its original ruling but reduced the suspension from 18 to 12 months. In affirming the ruling, the commission relied on the absolute-insurer rule of the Rules of Racing and the Louisiana Statutes, which makes horse trainers responsible for any doping of their horses, regardless of whether the trainer had anything to do with the doping or whether the trainer was negligent. The district court affirmed the ruling, and Arrington appealed. Arrington argued that the absolute-insurer rule violated his rights to due process because it created an irrebuttable presumption of guilt.
Rule of Law
Issue
Holding and Reasoning (Ward, J.)
Dissent (Barry, J.)
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