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Joe Gibbs Racing (JGR) has formally requested permission from the United States District Court for the Western District of North Carolina, presided over by Judge Susan C. Rodriguez, to file a second amended complaint in its ongoing lawsuit against Spire Motorsports and former employee Chris Gabehart. The proposed amendments center on Spire’s demonstrably improved performance in the NASCAR Cup Series during the 2026 season, which JGR contends is a direct consequence of Gabehart’s alleged breach of contract and misappropriation of trade secrets, facilitated by Spire’s creation of a purportedly misleading job title.
The core of JGR’s updated allegations, detailed within the proposed amended complaint, asserts that Spire’s decision to appoint Gabehart to the newly created position of "Chief Motorsports Officer" was a calculated maneuver designed to circumvent contractual obligations and gain an unfair competitive advantage. According to the filing, "Spire’s decision to create a bespoke and intentionally misleading title and role for Gabehart and hire him to that role was not motivated by a desire to further its competitive interests fairly. Rather, Spire’s decision to employ Gabehart was motivated by a desire to compete unfairly against JGR and to intentionally harm JGR’s competitive interests through unlawful means."
JGR further claims that Spire’s significant competitive uplift in the 2026 season is intrinsically linked to Gabehart’s alleged misappropriation of JGR’s proprietary information and trade secrets. The complaint states, "This sudden improvement in Spire’s Cup Series performance of course comes on the heels of Gabehart misappropriating JGR’s Confidential Information and Trade Secrets and providing Spire the same or similar services he provided JGR in the last year."
Objectively, Spire Motorsports has indeed experienced a notable upswing in competitive results during the 2026 NASCAR Cup Series season. Driver Carson Hocevar, under the Spire banner, has achieved a strong sixth-place standing in the championship points, including a victory at Talladega Superspeedway. This contrasts sharply with his 23rd-place finish in the final 2025 standings. Similarly, Daniel Suarez has piloted the No. 7 Spire Chevrolet to a 13th-place position in the current standings, a significant improvement over Justin Haley’s 31st-place finish in 2025. This enhanced performance coincides with Spire’s strategic investments, including the backing of private equity firm Group 1001, which has reportedly bolstered resources in personnel, facilities, and operational procedures.
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However, JGR’s legal challenge hinges on the assertion that Gabehart’s transition to Spire was not a legitimate career move but an orchestrated effort to leverage confidential information. The initial complaint detailed allegations that Gabehart saved numerous files from JGR’s servers to personal accounts and captured twenty cell phone photographs of sensitive company data prior to his departure. The court has since confirmed that Gabehart did indeed "misappropriate" these files. Nevertheless, a crucial point of contention remains: the court has not yet found evidence that these misappropriated files were disseminated to Spire or any other entity before the disclosure of their existence.
Spire Motorsports has consistently maintained its innocence throughout the legal proceedings, questioning its inclusion as a defendant in the initial complaint. Beyond the alleged file misappropriation, JGR has accused Spire of "tortious interference" with Gabehart’s employment contract with JGR. The defendants, however, argue that this contract was rendered void by JGR’s actions.
The proposed second amended complaint elaborates on these claims, stating, "Spire knowingly, intentionally, unjustifiably, and in bad faith induced Gabehart to breach his contract with JGR by (1) soliciting and hiring him to work for Spire, (2) requesting, encouraging, or otherwise inducing him to disclose or use Plaintiff’s trade secrets or confidential information, (3) allowing him to perform the same or similar services he provided JGR in the prior year to Spire and while using JGR’s Confidential Information and Trade Secrets, and on information and belief, actively encouraging and inducing him to do so and (4) creating a role specifically designed to allow Gabehart to breach his noncompete obligations in a manner that makes it more difficult to detect the breach of his noncompete obligations."
The original allegations, which described a "brazen scheme to steal JGR’s most sensitive information" in violation of various state statutes, have been progressively detailed through subsequent filings. The latest proposed amendments focus heavily on the "Chief Motorsports Officer" title. JGR contends that while this title might appear to signify a senior executive role akin to team ownership or management, Gabehart’s actual duties and responsibilities at Spire are allegedly indistinguishable from those of a competition director, thereby violating the non-compete clause in his former agreement with JGR. The defendants, conversely, maintain that these assertions are unfounded and that Gabehart is not performing activities prohibited by his contract.
JGR has consistently presented evidence, including what it describes as "constant surveillance" of Gabehart’s activities, to support its claim that his role at Spire mirrors that of a competition director. The amended complaint reiterates this point: "Spire’s decision to give Gabehart a different title while causing him to perform the same responsibilities he promised not to perform in the year following his departure from JGR was intended to harm JGR and to create a deceptive cover for Gabehart to violate his restrictive covenant in a way that is difficult to detect. These allegations further underscore the proposed Second Amended Complaint states a claim for tortious interference with contract against Spire." Furthermore, the filing states, "Last, the proposed Second Amended Complaint alleges Spire knew that Gabehart retained JGR’s trade secrets and confidential information and intended for him to use it for the benefit of Spire."
To proceed with this second amended complaint, the third iteration of the legal action, JGR requires either the consent of Spire Motorsports and Gabehart or the approval of Judge Rodriguez. As Spire and Gabehart have not consented, JGR is formally requesting the court’s permission. On May 1, 2026, Spire’s counsel informed JGR that they would oppose the motion to amend on grounds of futility. Gabehart’s counsel subsequently echoed this opposition, citing similar reasons.
The court typically grants leave to amend a complaint unless the moving party has acted in bad faith or the amendment would be futile. Spire and Gabehart appear to be challenging JGR’s motion on these latter two grounds.
In response to these objections, JGR argues that its proposed second amended complaint does not alter the fundamental nature of the claims against either defendant, nor does it modify the underlying legal theories or the requested relief. Instead, JGR asserts that the amendments primarily serve to incorporate additional factual details supporting the existing tortious interference with contract claim against Spire, many of which have emerged since the litigation commenced. JGR contends that these new allegations are known to the defendants and were partially addressed during preliminary injunction arguments. The plaintiffs maintain that these additions do not expand the scope of relief sought and that any opposition based on prejudice is unfounded, given the substantial overlap in factual support across all claims.
JGR further contends that its proposed amendment does not constitute bad faith, as defined by the Fourth Circuit. The racing organization states it is merely seeking to align its factual allegations with the developing record and the court’s prior comments. The amendment is also presented as a response to observations made by the court in its Preliminary Injunction Order issued on April 23, 2026.
Crucially, JGR argues that the amendment is not futile. While the defendants have not explicitly detailed their reasons for believing the amendment to be futile, JGR asserts that its proposed complaint adequately pleads each element of the tortious interference with contract claim under North Carolina law. These elements, as outlined by JGR, include: (1) a valid contract conferring a contractual right; (2) the defendant’s knowledge of the contract; (3) the defendant’s intentional inducement of the third party not to perform the contract; (4) action taken without justification; and (5) resulting actual damage to the plaintiff.
Adding another layer to the dispute, JGR has also taken issue with a social media post made by Spire Motorsports on its X account, which JGR believes trivialized the lawsuit and the initial complaint by referencing Spire’s sole win at the time. The post, which JGR characterizes as a "declaration" for social media rather than a formal court filing, allegedly mocked JGR’s allegations. JGR’s amended complaint states, "On April 27, 2026, Jeff Dickerson posted a document to his X account which purports to be an unfiled declaration, similar to those Spire has filed in this litigation. In the unfiled declaration, he appears to joke about the allegations in this lawsuit and brags about Spire’s first NASCAR Cup Series win since 2019 and second win ever. This sudden improvement in Spire’s Cup Series performance of course comes on the heels of Gabehart misappropriating JGR’s Confidential Information and Trade Secrets and providing Spire the same or similar services he provided JGR in the last year." This assertion directly links Spire’s social media activity to the core allegations of misappropriation and unfair competition.
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