Vasquez v. Paso Fino Horse Association Incorporated, 5:18-cv-00366

Background

Clara and Patricia Vasquez are sisters involved in a dispute over registration of a Paso Fino mare (Paz Del Suroeste) initially registered with Colombia’s Fedequinas and later with the U.S. Paso Fino Horse Association (PFHA).
Clara submitted the PFHA registration application (including the Fedequinas certificate); PFHA issued a 2008 certificate listing Clara and Patricia as co‑owners despite rules requiring initial registration in the name of the dam’s recorded owner at foaling.
Patricia later complained to PFHA alleging forgery; PFHA investigated, discovered an ownership error, and reissued the PFHA certificate naming the family farm (owned by Patricia) as the registered owner.
Clara filed this federal action seeking a declaratory judgment reinstating the original PFHA certificate naming the sisters as co‑owners; PFHA canceled its internal hearing because of the pending litigation and removed the sisters from the PFHA registry.
The court considered cross‑motions for summary judgment and evaluated (1) whether declaratory relief was appropriate and (2) whether PFHA’s change of registration was arbitrary and capricious under applicable association rules.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether declaratory relief regarding PFHA registration is appropriate	Vasquez: federal declaratory relief should resolve parties’ registry rights	PFHA: action may be procedural fencing and involves association rules better handled internally	Court: Declaratory relief appropriate — four of five Grand Trunk factors favor hearing the claim; no procedural‑fencing shown
Whether PFHA acted arbitrarily and capriciously in changing registered owner	Vasquez: PFHA should have followed disciplinary/hearing procedures before changing certificate; removal was unreasonable	PFHA: rules permit correction/cancellation of certificates for cause; no hearing required to correct an error	Court: PFHA’s correction (removing sisters) was not arbitrary re removal because Clara failed to show proper transfer paperwork; decision supported by substantial evidence in part; but transfer of Fedequinas certificate to PFHA registry was not supported by substantial evidence
Whether PFHA was required to request return of original certificate or hold hearing before changing ownership	Vasquez: rules required return of original certificate and hearing process under disciplinary rules	PFHA: rules allow correction for cause and do not require return of certificate or hearing for ownership corrections	Court: PFHA not required to request return nor to hold hearing before correcting certificate; its procedure was not clearly erroneous
Whether injunctive relief reinstating original certificate is appropriate	Vasquez: asks for injunction to reinstate original registration	PFHA: injunction improper — plaintiff has not prevailed and equities favor association	Court: Denied — Clara did not prevail on merits, would not suffer irreparable harm, and equities favor PFHA

Key Cases Cited

Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment standard)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment: genuine dispute standard)
Wilton v. Seven Falls Co., 515 U.S. 277 (discretion under Declaratory Judgment Act)
Grand Trunk W. R.R. Co. v. Consol. Rail Corp., 746 F.2d 323 (factors for declaratory relief)
Nat’l Collegiate Athletic Assoc. v. Lasege, 53 S.W.3d 77 (Kentucky standard for reviewing association decisions as arbitrary or capricious)