NASCAR News: Judge partially grants Joe Gibbs Racing injunction

A federal judge in the Western District of North Carolina has partially granted and partially denied a motion for a preliminary injunction filed by Joe Gibbs Racing (JGR) against its former employee Chris Gabehart (pictured) and Spire Motorsports.

–by Mark Cipolloni–

The ruling finds that JGR is likely to prevail on its key claims against Gabehart personally—including misappropriation of trade secrets and breach of his employment agreement—but stopped short of imposing similar restrictions on Spire Motorsports at this early stage.

The court determined that Gabehart improperly took JGR’s confidential information before his departure. This included highly sensitive competitive data such as race strategies, engineering analytics, financial details, and proprietary performance models. Evidence showed he copied or photographed the materials and stored them on personal devices without authorization. The judge ruled that these documents qualify as trade secrets and that Gabehart’s actions represented actual or threatened misappropriation. As a result, the injunction bars him from using or disclosing the information.

The court also upheld the enforceability of Gabehart’s noncompete clause, which prohibits him from performing similar services for competing NASCAR teams for up to 18 months. The judge found the agreement reasonable in scope and necessary to protect JGR’s legitimate business interests, given Gabehart’s senior role and extensive access to proprietary information. The injunction therefore restricts him from taking comparable positions with rival teams during the restricted period.

However, the judge denied JGR’s request for injunctive relief against Spire Motorsports itself. The court concluded there was insufficient evidence that Spire had acquired, used, or was likely to use JGR’s trade secrets. The judge explicitly rejected arguments based on the “inevitable disclosure” doctrine, noting that courts in the jurisdiction have not adopted it.

While the underlying lawsuit will continue toward a final decision on the merits, the ruling places immediate restrictions on Gabehart individually but leaves Spire free to operate without direct court-imposed limitations for now.

Gabehard JGR