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Eldridge v. Johndrow

Utah Supreme Court
345 P.3d 553 (2015)


Facts

The Eldridges (plaintiffs) owned residential property-management companies that catered to wealthy clients. Given the value of the assets, trust was an essential part of the Eldridges’ business relationships. David Johndrow (defendant) had referred several clients to the Eldridges before the two sides become involved in a personal dispute. Johndrow discovered that the Eldridges had liens, a foreclosure, an old felony conviction, and unflattering news reports from a different state. Johndrow threatened to reveal this true information to the clients that he had referred to the Eldridges unless the Eldridges retracted statements they had made about him and returned an allegedly stolen cell phone. The Eldridges did not agree, and Johndrow sent the truthful-but-embarrassing information to several of the Eldridges’ clients. The Eldridges sued Johndrow for intentionally interfering with their economic relations: (1) using improper means and (2) for an improper purpose. Johndrow moved for summary judgment on both claims. The district court dismissed the improper-means claim, finding that Johndrow’s distribution of truthful information was legal. However, the district court did not dismiss the improper-purpose claim, finding that: (1) an improper purpose could support a tortious-interference claim and (2) it was a factual question whether Johndrow had acted with an improper purpose. The case ended up in the Utah Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Durham, J.)

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