Mayfield v. National Ass'n for Stock Car Auto Racing, Inc.
2012 U.S. App. LEXIS 6158
| 4th Cir. | 2012Background
- Jeremy Mayfield, a NASCAR driver and team owner, challenges district court dismissal of his defamation, disability protection, UTPA, contract, and negligence claims arising from a positive methamphetamine drug test.
- Mayfield signed Driver/Owner Agreement, License Applications, and Driver/Owner Application before 2009; all contain a broad liability waiver and release NASCAR and related entities from claims.
- NASCAR’s Substance Abuse Policy requires random testing; tests identified methamphetamine, with A and B samples both positive after Mayfield’s May 2009 test.
- Mayfield alleged public statements by Brian France at a May 15, 2009 press conference defamed him; he also asserted various contract-based and tort theories.
- NASCAR moved for judgment on the pleadings; district court dismissed, citing waivers and failure to state a claim; NASCAR later voluntarily dismissed its counterclaims.
- Mayfield sought reconsideration and to amend, which the district court denied; this appeal followed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Waiver enforceability on claims | Mayfield argues waivers do not bar his claims for certain torts and contracts. | NASCAR contends waivers preclude claims as to all asserted theories. | Waiver enforceable; some counts barred |
| Defamation claim adequacy | Mayfield contends statements were malicious/false with actual malice. | NASCAR asserts statements were reporting results of valid drug tests and not made with actual knowledge of falsity. | Dismissed for failure to plead actual malice under Iqbal/Twombly |
| Post-judgment motions | Mayfield sought relief to amend; argues district court erred in denying amendment. | NASCAR contends amendments would be futile or prejudicial; new claims untimely. | District court did not abuse discretion; amendment denied |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (Supreme Court 2009) (plausibility standard governs pleading; general malice must still be pled with Rule 8)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (Supreme Court 2007) (requires plausibility, not just conceivable claim)
- N.Y. Times Co. v. Sullivan, 376 U.S. 254 (S. Ct. 1964) (public figures must show actual malice)
- Hatfill v. N.Y. Times Co., 416 F.3d 320 (4th Cir. 2005) (defamation pleading standards in the Fourth Circuit)
- Matrix Capital Mgm't Fund, LP v. BearingPoint, Inc., 576 F.3d 172 (4th Cir. 2009) (rules on post-judgment motions and amendments; interplay of Rule 59/60 and 15(a))
- Equal Rights Center v. Niles Bolton Assoc's, 602 F.3d 597 (4th Cir. 2010) (factors for prejudice in denying amendments; discovery considerations)
- Greater Orlando Aviation v. Bulldog Airlines, Inc., 705 So.2d 120 (Fla.Dist.Ct.App. 1998) (enforceability of liability waivers against some breach of contract claims)
- Ivey Plants, Inc. v. FMC Corp., 282 So.2d 205 (Fla.Dist.Ct.App.1973) (mutuality requirement for waivers on breach of contract)