The Court has issued a ruling on the discovery arguments surrounding an ongoing lawsuit between Joe Gibbs Racing and Spire Motorsports/Chris Gabehart.
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Back in February, Joe Gibbs Racing filed a lawsuit against Gabehart, the team's former competition director, alleging that he had embarked on a brazen scheme to steal confidential information and trade secrets. Joe Gibbs Racing also later named Spire Motorsports as a defendant.
Judge Susan C. Rodriguez has stated definitively that Gabehart, the Chief Motorsport Officer at Spire, had misappropriated competition and commercial data by continuing to access and store JGR information on personal drives. This happened after he had a meeting with Coach Joe Gibbs and parted ways with the team.
Gabehart also took photos of Joe Gibbs Racing information with his personal cell phone and accessed them before meetings with Spire Motorsports co-owner Jeff Dickerson.
The former JGR employee has maintained that he has not used any of this information and that he gave it all back to his former team. Dickerson has maintained that his team does not want this information, nor has it used it due to an existing alliance with Hendrick Motorsports.
The two sides in the lawsuit have disagreed about which documents they should produce as part of discovery, so United States Magistrate Judge David Keesler issued a ruling on several matters. He fully granted some motions and then partially denied others.
The Spire Motorsports Motions
- Spire Motorsports sought metadata from Joe Gibbs Racing regarding "allegedly misappropriated documents and original images of the documents screenshotted and/or photographed by Gabehart." The Court ruled that this must be produced by Oct. 9.
- Joe Gibbs Racing is directed to produce its full agreement with Toyota Racing Development — with an "appropriate tier of protection — by Oct. 13.
- Spire Motorsports sought the "economic value of allegedly misappropriated trade secrets" and monthly spreadsheets created by JGR Chief Financial Officer Tim Carmichael. The Court said JGR should supplement its response to include spreadsheets from January 2025.
- Finally, JGR is directed to provide Spire with one month of Chris Gabehart's emails from his time as crew chief and one month of emails from his time as competition director to provide a scope of his employment and duties at JGR.
- Spire sought identification of trade secrets "JGR contends were misappropriated by Gabehart and/or Spire." The Court directed JGR to fully identify the trade secrets at issue by Oct. 16.
- Spire contends that JGR has withheld five documents on the basis of privilege. JGR contends that it has produced redacted versions of two documents. The Court encouraged JGR to produce redacted versions of all five documents.
The Joe Gibbs Racing Motions
- The Court ruled that both Spire and JGR "should produce their final, as-raced, race car setup sheets for the 2025 and 2026 NASCAR Cup Series consistent with the appropriate procedures in the Amended Protective Order." The "misappropriated" setup information is a key issue in this case.
- JGR sought "additional technical documents (including run logs, car chief and driver debrief forms, competition meeting materials and missing attachments to competition meeting invitations and emails, lap analysis documents, EDRP/SMT data." Spire will have to produce all of this information, minus the EDRP/SMT data, for the races at Daytona, Atlanta, Kansas, and Circuit of the Americas, as well as other races that Gabehart attended.
- Spire is directed to produce materials from Monday morning meetings; NCS competition debrief meetings; engineering meetings; race strategy meetings; post-practice/post-qualifying meetings; and pre-event/race day meetings from those attended by Gabehart and those related to Daytona, Atlanta, Kansas, and COTA.
- JGR sought 20 specific categories of additional documents, but the Court denied this motion at this time.
The Chris Gabehart Motions
- Gabehart sought to compel TRD to respond to a subpoena and produce multiple documents. This included texts and emails from Andy Graves, Jack Irving, Slugger Labbe, and Tyler Gibbs.
- Gabehart specifically sought communication about his separation from JGR, his employment with Spire, and contemplated or anticipated litigation against him. The Court directed TRD to produce this communication.
- Gabehart sought communication between TRD and other NASCAR teams about him or Spire. The Court denied this request.
- He also sought contracts, "including but not limited to OEM or other similar agreements, between JGR and TRD or other related entities reflecting any technical support or services provided by TRD to JGR." The Court directed TRD to produce these documents.
- Gabehart also sought "any other documents or communications relating to the claims or defenses in this Lawsuit." The Court denied this request while calling it overly burdensome and broad.
"Respectfully, the Court wishes the Parties could resolve more of these discovery disputes on their own without Court intervention," wrote Judge Keesler.
"The Parties in this case litigate like they race - all out to win. That approach has certainly applied to discovery in this case, and while admirable to an extent, has likely contributed to delays and additional expense. That said, the Court does appreciate the efforts of counsel in advocating for their clients, and occasionally, resolving an issue by compromise."
