Is a Tire Pressure a Trade Secret? JGR’s Contempt Bid Puts Chris Gabehart’s Debrief Role on Trial

For most of 2026, Joe Gibbs Racing’s lawsuit against Chris Gabehart has been about stuff: photos snapped off a company laptop, a personal Google Drive folder labeled “Spire,” setup sheets and a 141-page post-race analysis that allegedly followed him out the door. The newest turn in the case is about something much harder to put in an evidence bag. It’s about what gets said in a room full of crew chiefs.

On Sept. 17, JGR asked the U.S. District Court for the Western District of North Carolina to hold Gabehart, Denny Hamlin’s longtime crew chief, and his current employer, Spire Motorsports, in contempt of the preliminary injunction the court entered in April. Spire answered the following evening with a statement from co-owner Jeff Dickerson on the team’s official X account, and the line that matters most was a blunt one: “JGR does not own tire pressures, JGR does not own race strategy.”

That sentence is the whole case in miniature. Strip away the shots traded between the two camps and what’s left is a question every team in the garage has a stake in: where does a crew chief’s know-how end and his old employer’s property begin?

What the April order actually says

Judge Susan C. Rodriguez’s April 23 preliminary injunction order (ECF No. 78 in case 3:26-cv-00133) split the difference in a way that shapes everything happening now. Against Gabehart, JGR won most of what it asked for. He was ordered to stop using or disclosing JGR’s confidential information and trade secrets, return anything he still had, and comply with Section 6 of his JGR employment agreement, the clause barring him from providing “services of the general type” he performed for JGR in his final year there to another Cup or Xfinity team.

Against Spire, JGR got nothing. The court found no showing that Spire acquired, used or disclosed JGR trade secrets, and it declined to lean on the “inevitable disclosure” theory, the idea that a hire like Gabehart can’t help but carry his old team’s secrets into the new building. The order also spelled out what Section 6 does not require: Gabehart didn’t have to resign from Spire, and he wasn’t barred from going to the racetrack.

That leaves a lot riding on the phrase “general type.” In his last year at JGR, Gabehart wasn’t just a crew chief. He’d been promoted to competition director in December 2024 and also called races for the No. 54 for part of 2025. Spire signed him in February 2026 as Chief Motorsports Officer. A competition director’s job is, more or less, sitting in the meetings where cars get picked apart and rebuilt. If he’s sitting in the same meetings at Spire, JGR’s argument writes itself. If he’s there as an executive running the business side while engineers talk springs, Spire’s does too.

How a qualifying tire pressure ended up in a federal court file

The best window into what JGR thinks happened is a six-page notice JGR filed on Aug. 27 (ECF No. 158). It cites the Aug. 25 deposition of Travis Peterson, crew chief of Spire’s No. 71 Chevrolet driven by Michael McDowell. JGR says Peterson testified that early in the 2026 season he asked Gabehart how Spire’s qualifying tire pressures compared with JGR’s, because he was wondering whether Spire needed to run higher, and that Gabehart told him. The filing says spring settings came up too.

Spire’s position, from Dickerson’s statement, is that numbers like that aren’t anyone’s property. Neither side’s framing is settled law yet, and that’s the point. Trade secret status under the Defend Trade Secrets Act turns on whether information has value because competitors don’t know it and whether the owner took reasonable steps to keep it secret. A single tire pressure from one qualifying session is a much harder sell than a folder of full setup sheets. A pattern of them, fed to a rival crew chief week after week, is a different conversation.

Why a number this small is worth fighting over

If you’re wondering why a Cup team would go to federal court over a few psi, look at the car. The Next Gen platform turned most of the major components into single-source spec parts. Teams can’t build their own chassis, suspension geometry or aero pieces the way they could in the Gen-6 era. What’s left to play with is a narrow band of setup variables: springs, shocks, alignment, ride heights, tire pressures. When the car is 90% identical across the field, the last 10% is where the entire competitive advantage lives.

Tire pressure is one of the most sensitive of those levers. Goodyear sets a minimum recommended inflation for each weekend; what a team actually runs above that floor affects grip, heat build, wear and how the car balances over a run. Qualifying pressures are their own art, because teams are chasing one lap of peak grip, not 60 laps of durability. Knowing where a front-running Toyota team sets its qualifying pressures at a given track is useful. Knowing how that team arrived at the number is more useful still, and that process is exactly what a competition director oversees.

Contempt is a high bar, and Spire is the harder target

Civil contempt in the Fourth Circuit requires the moving party to prove its case by clear and convincing evidence: a valid order the other side knew about, a violation of its terms, and harm to the movant. That’s a tougher standard than the “likelihood of success” test JGR cleared to get the injunction in the first place. A judge who already drew a careful line around what Gabehart can do at Spire will want to see that he actually crossed it, not just that he stood near it.

Spire is a trickier target still, because the April order didn’t enjoin Spire at all. Under Federal Rule of Civil Procedure 65(d), an injunction can still bind non-parties who act “in active concert or participation” with an enjoined party and have actual notice of the order. That’s the door JGR has to push open: showing Spire didn’t merely employ Gabehart but put him to work in a way that helped him violate the injunction. Dickerson’s statement argued the court has already turned down JGR’s bids to restrain Spire twice. A contempt finding would be a much bigger swing than either of those.

The Toyota-Chevrolet subplot

This isn’t a squabble between two teams in the same camp. JGR is Toyota’s flagship Cup operation. Spire races Chevrolets and works in a technical alliance with Hendrick Motorsports. Any knowledge moving from one side to the other crosses a manufacturer line, which is why Toyota Racing Development has been pulled into discovery. A motion to compel aimed at TRD hit the docket in August, and TRD has its own outside counsel in the case.

For the rest of the garage, the stakes are bigger than one crew chief. NASCAR’s talent market runs on people changing shops. If Section 6-style clauses can reach into what a new hire says in a debrief, every competition director, crew chief and lead engineer who changes teams will be negotiating over what they’re allowed to say. If they can’t, teams will lean harder on the file-and-device protections that got JGR its injunction in the first place. Either outcome will be read closely by every team owner with a non-compete in a drawer.

Spire has been in the spotlight all season, from its public back-and-forth with Denny Hamlin to its move to put Corey Day in a Spire Chevrolet for his Cup debut. For how the Gabehart dispute started, see our look at the handshake “trade” behind the lawsuit.

What to watch

• How the court defines “general type.” Any ruling on the contempt motion will effectively tell Gabehart, and Spire, which rooms he can and can’t be in for the rest of the restriction period.
• Whether Spire gets roped in. A finding that Spire acted in concert with Gabehart would be JGR’s first real win against the team itself.
• The calendar. The court’s case management order set a mediation deadline of Oct. 23, a dispositive-motions deadline of Oct. 30 and a nine-day jury trial starting Feb. 1, 2027.
• Why JGR won’t let this go. Gabehart and Hamlin won 22 Cup races together, including back-to-back Daytona 500s in 2019 and 2020. JGR knows exactly what his knowledge is worth. That’s why it’s still fighting over it.

About the Author

Kyle Matthews

Author

Kyle Matthews is a staff writer at Backfire Racing, focusing on NASCAR coverage with additional reporting on Formula 1, IndyCar, and endurance racing.

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