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Marrone v. Washington Jockey Club

Citation. 227 U.S. 633 (U.S. 1913)
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Brief Fact Summary.

Marrone sued for trespass claiming that his ticket to an event gave him property rights to the venue at which the event was being held.

Synopsis of Rule of Law.

Buying a ticket to an event does not give the purchaser a property interest in the venue.

Facts.

Marrone bought a ticket to a racetrack owned by Washington Jockey Club (Washington) and was prevented entry into the race track after being accused of drugging one of the horses. Marrone sued for trespass and the lower court ruled for Washington. Marrone appealed.

Issue.

Whether buying a ticket to an event gives the purchaser a property interest in the venue?

Held.

No. The judgment of the lower court is affirmed. Marrone did not have the right to demand access to any part of the racetrack because the ticket did not convey any part of the racetrack to Marrone.

Discussion.

Buying a ticket creates a contract but the ticket does not create a property interest. Marrone’s only redress was to sue for breach of contract because the ticket created a contract for entry.


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