CHARLOTTE, N.C. – Joe Gibbs Racing (JGR) is petitioning the U.S. District Court for the Western District of North Carolina to allow a second amended complaint in its ongoing legal battle against Spire Motorsports and former competition director Chris Gabehart. The racing powerhouse alleges that Spire’s significant performance gains in the 2026 NASCAR Cup Series season are a direct result of hiring Gabehart under a deliberately misleading title, thereby violating a non-compete agreement, and through the alleged misappropriation of JGR’s proprietary competition data.
The core of JGR’s argument, as detailed in its proposed amended complaint, centers on Spire’s creation of the role of "Chief Motorsports Officer" for Gabehart. JGR contends that this title and subsequent hiring were not motivated by a genuine pursuit of fair competition but rather a calculated strategy to gain an unfair advantage and intentionally undermine JGR’s competitive interests through illicit means.
“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,” the proposed filing states. JGR further asserts that this marked improvement in Spire’s Cup Series performance directly follows Gabehart’s alleged misappropriation of JGR’s confidential information and trade secrets, enabling him to provide services to Spire similar to those he rendered to JGR in the preceding year.
Objective data from the 2026 NASCAR Cup Series season illustrates a marked upward trajectory for Spire Motorsports. Driver Carson Hocevar, now sixth in the standings, has secured a victory at Talladega Superspeedway, a significant leap from his 23rd place finish in the 2025 final standings. Similarly, Daniel Suarez has piloted the No. 7 Spire car to 13th in the standings this season, a considerable improvement over Justin Haley’s 31st place finish in the 2025 final standings. This surge in performance coincides with Spire’s investment in personnel, facilities, and procedures, bolstered by an ownership group that includes private equity firm Group 1001. However, JGR maintains that Gabehart’s recruitment was unlawful.
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These allegations are an expansion of JGR’s initial claims, which outlined a "brazen scheme to steal JGR’s most sensitive information." The original complaints detailed accusations that Gabehart saved numerous files from JGR’s servers to personal accounts and captured 20 cell phone photographs of sensitive data. While the court has factually confirmed that Gabehart "misappropriated" these files, it has also stated that no current evidence suggests these files were disseminated to Spire or any other entity prior to their disclosure in the legal proceedings.
Spire Motorsports has consistently maintained its innocence throughout the litigation, expressing bewilderment at its inclusion as a defendant in the amended complaint. Beyond the misappropriated files, JGR has accused Spire of "tortious interference" with Gabehart’s contractual obligations to JGR. The defendants, however, argue that Gabehart’s contract with JGR was rendered void by his former employer.
The proposed second amended complaint elaborates on this accusation: “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 crux of JGR’s latest filing lies in its interpretation of Gabehart’s role at Spire. While Spire has appointed Gabehart as "Chief Motorsports Officer," a title that ostensibly places him in a senior executive capacity akin to a team owner or high-level manager, JGR asserts that his actual responsibilities align with a competition-focused role, thereby violating the terms of his non-compete agreement. JGR claims to have monitored Gabehart’s activities extensively, arguing that his actions demonstrate he is performing duties inconsistent with the spirit, if not the letter, of his contractual restrictions.
“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,” the filing argues. JGR also alleges that Spire was aware Gabehart retained JGR’s trade secrets and confidential information and intended for him to utilize it for Spire’s benefit.
To advance this second amended complaint, the third iteration of the legal filing, JGR requires either the consent of the defendants or the approval of Judge Susan C. Rodriguez. As Spire and Gabehart have not consented, JGR is formally requesting the court’s permission.
"Shortly before 5:00 p.m. Eastern Time on May 1, 2026, Spire’s counsel informed JGR’s counsel that Spire did not consent to the proposed amendment," the motion details. "JGR’s counsel responded shortly thereafter to ask the basis for Spire’s opposition to confer on whether an agreement could be reached, obviating the need for Court intervention. On Monday May 4, 2026, Spire counsel responded that it would oppose the Motion to Amend on futility grounds. Despite the fact the proposed Second Amended Complaint does not amend any claims against Gabehart, his counsel also informed JGR’s counsel on May 4, 2026, that he opposed the amendment for the same reasons Spire offered."
The legal standard for denying a plaintiff an amended filing typically involves the commencement of fact discovery or evidence of the moving party acting in bad faith or the amendment being futile. Spire and Gabehart are reportedly leveraging these latter two grounds to oppose JGR’s request.
In response, JGR argues that its proposed amendment does not alter the fundamental nature of the claims, the underlying legal theories, or the requested relief. Instead, it aims to incorporate additional factual allegations pertinent to the tortious interference with contract claim against Spire, many of which occurred after the litigation commenced. JGR asserts that these new facts are known to the defendants and were, in part, presented during preliminary injunction arguments. The racing team contends that these additions do not expand the scope of relief sought and that there is substantial overlap with existing factual allegations, thus negating any claim of prejudice against the defendants.
"JGR’s proposed amendment cannot be said to even approach the threshold of what the Fourth Circuit outlines as being offered in bad faith," JGR argues in its motion. "JGR is simply seeking to ensure that its factual allegations reflect the nature of the claims and their overall severity, in line with the factual record as it develops. The amendment is also made in response to comments made by the Court in its Preliminary Injunction Order, issued on April 23, 2026."
Furthermore, JGR contends the amendment is not futile, asserting that the proposed Second Amended Complaint adequately alleges each element of the tortious interference with contract claim under North Carolina law. These elements include: (1) a valid contract conferring a contractual right; (2) the defendant’s knowledge of the contract; (3) intentional inducement of breach without justification; and (4) resulting actual damage to the plaintiff. JGR maintains that its proposed amendments sufficiently address these criteria.
Adding another layer to the dispute, JGR has also taken issue with a social media post made by Spire Motorsports on its X account. The post, which JGR claims was a facetious declaration in response to the lawsuit, alluded to Spire having only one win. JGR’s filing 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." JGR reiterates its assertion that this performance surge is directly linked to Gabehart’s alleged actions.
The legal proceedings are ongoing, with the court’s decision on JGR’s motion to amend the complaint pending. The outcome could significantly shape the trajectory of the litigation and the competitive landscape within the NASCAR Cup Series.
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