## Facts

- Bobby Edward Arrington was licensed under Louisiana law as a racehorse owner and trainer.
- On March 3, 1983, a horse owned and trained by Arrington finished second in a race at Evangeline Downs, making the horse eligible to share in the purse.
- A post-race urine analysis reported methamphetamine, a prohibited drug under the Louisiana Rules of Racing.
- Arrington requested a second (split-sample) test, which also returned positive for methamphetamine.
- The Board of Stewards at Evangeline Downs suspended Arrington’s racing privileges.
- Arrington appealed to the Louisiana State Racing Commission, which suspended Arrington’s owner and trainer licenses for 18 months and imposed a $500 fine.
- The Orleans Parish Civil District Court affirmed the Commission, but on a motion for new trial remanded for a rehearing so evidence of the split-sample results could be heard.
- After rehearing, the Commission again found Arrington liable under the “absolute insurer” rule but reduced the suspension from 18 months to 12 months and left the $500 fine in place.
- The district court affirmed the Commission’s ruling on remand, and Arrington appealed to the Louisiana Court of Appeal, Fourth Circuit.
- Arrington contended the absolute-insurer rule violated due process by treating the presence of a prohibited drug as an irrebuttable presumption that the trainer was responsible, even absent knowledge, intent, or negligence.

## Issues

1. Whether the Louisiana Rules of Racing and statutes establishing an “absolute insurer” rule violate due process by effectively creating an irrebuttable presumption that a trainer is responsible whenever a horse tests positive for a prohibited substance, regardless of fault.

## Decision

- The Court of Appeal affirmed the district court’s judgment upholding the Commission’s order.
- The court held the absolute-insurer rule constitutional as applied in the Commission’s disciplinary process.
- The court rejected the argument that due process required proof of Arrington’s knowledge, intent, or negligence before discipline could be imposed.
- The court upheld the 12-month suspension of Arrington’s owner and trainer licenses and the $500 fine.

## Legal Principles

- A racing commission may treat a trainer as the “absolute insurer” of a horse’s condition: if a prohibited drug is found in the horse, discipline may be imposed without proof of the trainer’s knowledge, intent, or negligence.
- Due process permits strict-liability-type licensing conditions in heavily regulated activities when the rule is reasonably related to legitimate governmental objectives such as fair and safe racing, the wagering public’s protection, and public confidence in racing integrity.
- Racing commission proceedings are civil administrative actions governed by the Administrative Procedure Act, not criminal prosecutions; accordingly, criminal-trial protections and mens rea requirements do not apply in the same way.
- A trainer who voluntarily seeks and holds a license may be subject to stringent regulatory conditions that would be inappropriate outside the licensing context.
- Prior precedent upholding the same rule on similar facts (including Owens v. Louisiana State Racing Commission) may control the outcome when the legal challenge is materially the same.

## Conclusion

The Fourth Circuit affirmed sanctions against Arrington after a confirmed methamphetamine-positive test, holding that Louisiana’s absolute-insurer rule validly assigns trainers strict responsibility for prohibited substances in their horses as a reasonable condition of participation in a closely regulated racing industry, and that due process does not require proof of fault before imposing administrative discipline.


Arrington v. Louisiana State Racing Comm'n, 482 So.2d 200 (1986)