Mayfield v. National Ass’n for Stock Car Auto Racing, Inc., No. 10-2437

Decided Mar. 26, 2012

NASCAR driver Jeremy Mayfield tested positive for methamphetamines during a routine drug test. NASCAR indefinitely suspended Mayfield and announced its decision during a press conference where the organization asserted he had taken “a ‘performance enhancing’ or ‘recreational’ drug.” Mayfield claimed the positive result came from Claritin-D and Adderall. He sued NASCAR alleging, inter alia, breach of contract and defamation. The district court granted judgment to NASCAR on the pleadings, finding that Mayfield had contracted away his ability to sue.

On appeal, the Fourth Circuit affirmed. Mayfield had signed various contract clauses agreeing to submit to random drug testing and holding NASCAR harmless for the policy’s implementation or dissemination of information to third parties. Also, the district court did not abuse its discretion by dismissing (and refusing to allow an amendment) Mayfield’s defamation claim because the Complaint did not articulate a plausible claim for relief that included “malice” on the part of NASCAR in publicizing his suspension.

Full Opinion

-C. Alexander Cable

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