## Facts

- Harlan Youst owned “Bat Champ,” entered in a harness race at Hollywood Park; Gerald Longo drove a competing horse, “The Thilly Brudder.”
- Youst alleged Longo drove into Bat Champ’s path and struck Bat Champ with a whip, causing Bat Champ to break stride.
- Bat Champ finished sixth and The Thilly Brudder finished second.
- The California Horse Racing Board reviewed the incident, disqualified The Thilly Brudder, and advanced Bat Champ to fifth place, resulting in a $5,000 purse for Youst.
- Youst sued Longo for negligent interference, intentional interference, and conspiracy, seeking compensatory and punitive damages for the lost chance to win a larger purse.
- The trial court sustained a general demurrer without leave to amend and dismissed; the Court of Appeal affirmed; the California Supreme Court granted review.

## Issues

1. Whether a racehorse owner may recover tort damages for negligent or intentional interference with prospective economic advantage based on interference with the chance of winning a larger purse in a horse race.
2. Whether the California Horse Racing Board has statutory authority to award compensatory or punitive damages for such conduct.

## Decision

- The dismissal was affirmed.
- A tort claim seeking damages for interference with the chance of winning a contest purse is not cognizable because the alleged economic expectancy is too uncertain and speculative.
- As a matter of public policy, claims for interference with prospective economic advantage based on conduct occurring during a sporting contest ordinarily will not lie.
- The California Horse Racing Board lacks authority to award compensatory or punitive damages; its authority is regulatory and disciplinary.

## Legal Principles

- Interference-with-prospective-economic-advantage liability requires a non-speculative economic expectancy; a mere chance of winning a contest prize is ordinarily too uncertain to support tort damages.
- Courts generally bar tort claims premised on alleged in-contest interference in competitive sports to avoid expansive and impractical civil litigation over ordinary competitive conduct.
- An administrative sports regulator’s remedial powers are limited to those granted by statute; absent express authorization, it may regulate and discipline participants but may not adjudicate private tort damages.

## Conclusion

California does not allow tort recovery for the loss of a speculative chance to win a greater race purse, and it generally rejects interference-with-expectancy suits arising from conduct during sporting contests; the racing board may discipline and adjust results but cannot award civil damages.


Youst v. Longo, 43 Cal. 3d 64 (Cal. 1987)