Crouch v. NASCAR
United States Court of Appeals for the Second Circuit
845 F.2d 397 (1988)
- Written by Craig Conway, LLM
Facts
Robert Crouch (plaintiff) was declared the winner of the 1985 stock car race held in Vermont, sponsored by the National Association of Stock Car Auto Racing (NASCAR) (defendant). Another driver, Randy LaJoie (defendant), actually crossed the finish line ahead of Crouch, but was disqualified by a NASCAR official at the track. LaJoie appealed the ruling and after a brief investigation, NASCAR declared LaJoie the winner. Crouch brought suit, challenging NASCAR’s decision under the association’s own constitution. Although every racing entrant, including Crouch, was required to sign a form that stipulated he would abide by the decisions of racing officials and that such decisions were not appealable and non-litigable, the district court granted relief to Crouch on the theory that NASCAR’s interpretation and application of its own rules was “unreasonable and arbitrary.” NASCAR and LaJoie appealed.
Rule of Law
Issue
Holding and Reasoning (Meskill, J.)
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