## Facts

- Marrone bought admission tickets to the Bennings Race Track in the District of Columbia on two successive days.
- On the first day, the Washington Jockey Club’s agents forcibly prevented Marrone from entering despite his ticket.
- On the second day, Marrone was prevented from entering or removed immediately after depositing his ticket in the admission box.
- Marrone sued in trespass for the forcible exclusion/ejection.
- Marrone also asserted a separate claim alleging the defendants conspired to destroy his reputation by excluding him on an accusation that he had drugged (“doped”) a horse he entered in a prior race.
- At trial, no evidence supported the alleged conspiracy, and the force used was limited to what was necessary to keep Marrone off the premises.

## Issues

1. Whether purchase of an admission ticket to a place of entertainment creates a property right (a right in rem) to enter such that exclusion or ejection constitutes trespass by the land possessor.
2. If no property right is created, whether the ticket holder’s remedy for wrongful exclusion lies in contract rather than trespass.
3. Whether the evidence was sufficient to support a conspiracy claim based on reputational injury from the exclusion.

## Decision

- The Supreme Court affirmed the judgment for the Washington Jockey Club.
- An admission ticket to a place of entertainment does not create a right in rem in the premises.
- The ticket operates, at most, as a revocable license supported by contract; it is not a conveyance of an interest in land.
- Because Marrone had no property interest or irrevocable right of entry, he could not maintain trespass based on being excluded or removed.
- Any remedy for wrongful refusal of admission was an action for breach of contract, not self-help entry followed by a trespass claim.
- The conspiracy claim failed because no evidence of a conspiracy was introduced.

## Legal Principles

- A ticket to a place of entertainment for a specified time generally confers only a revocable license, not a property interest in the premises.
- Contractual arrangements bind persons but do not create property interests unless they also operate as a conveyance.
- When a license is revocable, the holder cannot compel entry by self-help; the remedy for wrongful revocation is damages for breach of contract.
- An irrevocable right of entry may arise only when the contract is incidental to an existing property interest (e.g., a conveyance-related right), not when the admission contract stands alone.
- Claims of reputational conspiracy require proof of the alleged agreement and acts; absent evidence, the claim fails.

## Conclusion

The Court held that an admission ticket creates only contractual rights and a revocable license to enter, not a property right enforceable through trespass; therefore, the proper remedy for wrongful exclusion is a contract action, and the separate conspiracy claim failed for lack of evidence.


Marrone v. Washington Jockey Club, 227 U.S. 633 (1913)