Della Penna v. Toyota Motor Sales, U.S.A., Inc.
Supreme Court of California
902 P.2d 740 (Cal. 1995)
In order to protect its sales interests in Japan, Toyota Motor Sales, U.S.A., Inc. (Toyota) (defendant) put a clause in its dealership agreements that prohibited dealers from selling Lexuses (a Toyota subsidiary) to customers outside the United States. John Della Penna (plaintiff) owned a Toyota dealership and made a good profit buying Lexuses at retail and exporting them to Japan for resale. After finding out about Della Penna’s and other similar businesses, Toyota sent a letter to all of its Lexus dealers containing an “offenders” list of dealers involved in exporting Lexuses. The list included Della Penna and the letter stated that doing business with anyone on the “offenders” list could lead to sanctions from Toyota. Thereafter, Della Penna’s exporting partners began to refuse to do business with him. Della Penna brought suit, alleging tortious interference with his economic relations. The trial court’s jury instructions included a requirement that Della Penna prove that Toyota’s alleged interference was wrongful. The jury found in favor of Toyota. The court of appeal reversed, holding that wrongfulness is not a required element of interference with prospective contractual relations. The Supreme Court of California granted Toyota’s petition for review.
Rule of Law
Holding and Reasoning (Arabian, J.)
Concurrence (Mosk, J.)
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