Friday, November 8, 2013

Crouch v. NASCAR case brief

Crouch v. NASCAR case brief summary
845 F.2d 397 (1988)

Appellants stock car racing association and driver challenged an order of the United States District Court for the District of Vermont, which granted the summary judgement motion of appellees, owner and driver, for declarative and injunctive relief against appellants for appellant stock car racing association's alleged breach of its duties to fairly manage a stock car race and to comply with its membership contract's rules and regulations.

Appellee driver was declared the winner in a stock car race. Appellant driver challenged the decision due to irregularities during the race and appellant stock car racing association declared appellant driver the winner. Appellees, owner and driver, were granted their motion for summary judgement that appellant stock car racing association violated an internal rule that gave finality over race procedure decisions to local officials and it acted unreasonably in overturning the decision of the local officials.

  • The court held that judicial review of the decisions of private associations was appropriate only where the association did not have procedural safeguards to protect its members' interests or where the association acted in bad faith. 
  • The court held the lower court was not authorized to overrule an association's interpretation of its own procedural rules. 
  • The court held that appellees had not claimed any deprivation of a procedural safeguard nor was there any evidence of bad faith by appellant stock car racing association. 
  • The court reversed and vacated the judgement. It remanded with directions to grant appellants' summary judgement motion and dismiss the complaint.


The court reversed and remanded for the lower court to grant summary judgement to appellants, driver and stock car racing association, and to dismiss the complaint filed by appellees, owner and driver. The court held that the lower court did not apply the proper standard of judicial review for appellant stock car racing association's decisions.

Suggested Study Aid For Sports Law

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