Eldridge v. Johndrow
2015 UT 21, 2015 Utah LEXIS 67, 345 P.3d 553 (2015)
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Rule of Law:
A claim for intentional interference with economic relations requires proof that the defendant used improper means; a plaintiff cannot succeed based solely on the defendant's improper purpose or malicious motive.
Facts:
- Joseph and Lindsey Eldridge owned and operated a property management company for wealthy clients.
- David Johndrow, a former friend and client of the Eldridges, became involved in a dispute with them involving mutual accusations.
- Following the dispute, Johndrow hired an investigative team that uncovered embarrassing but true information about the Eldridges' past, including financial liens, a foreclosure, and an old felony conviction.
- Johndrow threatened to reveal this information to the Eldridges' clients unless they retracted their accusations against him and compensated him for an allegedly stolen phone.
- When the Eldridges refused his demands, Johndrow disseminated the damaging, truthful information via email to at least nine of their institutional clients and verbally to several individual clients.
Procedural Posture:
- Joseph and Lindsey Eldridge sued David Johndrow in a Utah district court, alleging tortious interference with economic relations, among other claims.
- Johndrow filed a motion for summary judgment.
- The district court granted summary judgment for Johndrow on the Eldridges' claims based on 'improper means,' finding the information he disseminated was substantially true and not defamatory.
- The district court, however, denied Johndrow's motion for summary judgment on the claims based on 'improper purpose,' citing binding precedent that allowed such claims.
- Johndrow, as the appellant, filed an interlocutory appeal of that denial to the Supreme Court of Utah, with the Eldridges as appellees.
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Issue:
Does a claim for tortious interference with economic relations succeed under Utah law when it is based solely on the defendant's alleged improper purpose, without any accompanying evidence of improper means?
Opinions:
Majority - Justice Durham
No. A claim for tortious interference with economic relations cannot succeed without evidence of improper means. The court overrules prior precedent and rejects the 'improper purpose' doctrine as an independent basis for liability. This doctrine is abandoned because it is vague, creates unpredictable verdicts, and requires juries to speculate on a defendant's subjective motivations, insulating their findings from meaningful appellate review. Furthermore, allowing liability based on malice alone creates a 'chilling effect' on socially beneficial conduct and the free exchange of truthful information. The proper standard requires a plaintiff to prove the defendant engaged in objectively wrongful conduct, such as an act that is independently tortious or illegal, to interfere with their economic relations.
Analysis:
This decision marks a significant shift in Utah's tortious interference jurisprudence by eliminating the 'improper purpose' prong as a standalone basis for liability. It overrules Pratt v. Prodata and clarifies the foundational case of Leigh Furniture, aligning Utah with a modern trend that favors objective standards of wrongful conduct over subjective inquiries into motive. This change enhances legal predictability for businesses and individuals, providing a clearer line between aggressive-but-lawful competition and tortious conduct. The ruling aims to prevent the 'chilling effect' that vague, motive-based torts can have on the free exchange of truthful information and legitimate commercial activities.
