A federal judge in the Western District of North Carolina has granted in part and denied in part a motion for a preliminary injunction filed by Joe Gibbs Racing (JGR) against former employee Chris Gabehart and Spire Motorsports. The ruling finds that JGR is likely to succeed on key claims against Gabehart, including misappropriation of trade secrets and breach of his employment agreement, but declines to extend similar relief to Spire at this stage.
The court determined that Gabehart improperly acquired JGR’s confidential information before his departure, including sensitive competitive data such as race strategy, engineering analytics, financial details, and proprietary performance models. Evidence showed he copied or photographed this information and stored it on personal devices without authorization. The judge concluded that these materials qualify as trade secrets and that Gabehart’s actions constitute actual or threatened misappropriation, warranting injunctive relief restricting his use or disclosure of the information.
In addition, the court upheld the enforceability of Gabehart’s noncompete agreement, which restricts 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 business interests, particularly given Gabehart’s high-level role and access to sensitive information. As a result, the injunction will also limit his ability to work in comparable positions during the restricted period.
However, the court denied JGR’s request for injunctive relief against Spire Motorsports, finding insufficient evidence that the team had acquired, used, or was likely to use JGR’s trade secrets. The judge rejected arguments based on the “inevitable disclosure” theory, noting that courts in the jurisdiction have not adopted that doctrine. While the case will proceed on the merits, the ruling maintains restrictions on Gabehart individually while allowing Spire to continue operations without direct court-imposed limitations at this time.
A federal judge in the Western District of North Carolina has granted in part and denied in part a motion for a preliminary injunction filed by Joe Gibbs Racing (JGR) against former employee Christopher Gabehart and his new employer, Spire Motorsports. The ruling finds that JGR is likely to succeed on key claims against Gabehart, including misappropriation of trade secrets and breach of his employment agreement, but declines to extend similar relief to Spire at this stage.
The court determined that Gabehart improperly acquired JGR’s confidential information before his departure, including sensitive competitive data such as race strategy, engineering analytics, financial details, and proprietary performance models. Evidence showed he copied or photographed this information and stored it on personal devices without authorization. The judge concluded that these materials qualify as trade secrets and that Gabehart’s actions constitute actual or threatened misappropriation, warranting injunctive relief restricting his use or disclosure of the information.
In addition, the court upheld the enforceability of Gabehart’s noncompete agreement, which restricts 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 business interests, particularly given Gabehart’s high-level role and access to sensitive information. As a result, the injunction will also limit his ability to work in comparable positions during the restricted period.
However, the court denied JGR’s request for injunctive relief against Spire Motorsports, finding insufficient evidence that the team had acquired, used, or was likely to use JGR’s trade secrets. The judge rejected arguments based on the “inevitable disclosure” theory, noting that courts in the jurisdiction have not adopted that doctrine. While the case will proceed on the merits, the ruling maintains restrictions on Gabehart individually while allowing Spire to continue operations without direct court-imposed limitations at this time.
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