## Facts

- A NASCAR-sanctioned 100-lap stock car race occurred at Catamount Speedway in Vermont on August 11, 1985.
- Robert A. Crouch drove a car owned by Glen A. Wright; Randy LaJoie was a competing driver.
- Local track officials initially declared Crouch the winner after disqualifying LaJoie based on alleged rule violations and disputed scoring events, including a restart and later caution-flag passing questions.
- NASCAR operated through a membership/license arrangement under which entrants agreed to follow NASCAR rules and accept officials’ decisions as “final,” “not subject to appeal,” and “non-litigable.”
- NASCAR’s rules addressed finality of certain “race procedure” decisions by local officials and also described authority of national officials within NASCAR’s internal structure.
- After internal review, national NASCAR officials overturned the local determination and declared LaJoie the winner.

## Issues

1. What is the proper standard for judicial review of a private sporting association’s decision on race results when participants contractually accept officials’ decisions as final.
2. Whether a court may overturn NASCAR’s internal decision by applying a broad “reasonableness” review of NASCAR’s interpretation of its own rules.
3. Whether national NASCAR officials lacked authority under NASCAR’s rules to revise local officials’ determinations regarding the winner.

## Decision

- The Second Circuit reversed the district court’s summary judgment for Crouch and Wright.
- The court held the district court applied an incorrect standard by using an expansive “reasonableness” review of NASCAR’s decision.
- Applying limited judicial review appropriate to private associations and the parties’ finality agreement, the court concluded NASCAR’s action was within its authority and not subject to being set aside on mere disagreement with rule interpretation.
- The court remanded with instructions to enter judgment for NASCAR and LaJoie.

## Legal Principles

- Decisions of private, voluntary associations—especially sports-governing bodies—receive substantial judicial deference when made within the association’s authority and not tainted by fraud, bad faith, or violation of public policy.
- Where participants agree by contract that officials’ decisions are final and non-appealable, judicial review is extremely limited.
- Courts generally will not act as referees over technical competition rules; review focuses on whether the association acted within its rules and authority, followed its basic procedures, and did not act in fraud or bad faith.
- A court should not substitute its own interpretation of a sports association’s rulebook for the association’s interpretation absent a showing that the association acted outside its delegated powers or engaged in misconduct.

## Conclusion

The Second Circuit held that race-result disputes governed by a private association’s rules and an entrant’s agreement to final, non-litigable decisions are largely insulated from judicial second-guessing; absent fraud, bad faith, or action beyond delegated authority, courts must defer to the association’s determination and may not invalidate it based on a general “reasonableness” assessment.


Crouch v. Nat’l Ass’n for Stock Car Auto Racing, Inc., 845 F.2d 397 (2d Cir. 1988)