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Janvrin v. Continental Resources, Inc.

934 F.3d 845 (2019)

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Janvrin v. Continental Resources, Inc.

United State Court of Appeals for the Eighth Circuit

934 F.3d 845 (2019)

Facts

Jerry Janvrin (plaintiff) owned J&J Trucking (J&J), a trucking company that hauled oil equipment. Most of J&J’s business came from CTAP, LLC, an oil-equipment supplier with multiple supply terminals, including one in Bowman, North Dakota. J&J hauled nearly exclusively out of CTAP’s Bowman terminal. Continental Resources, Inc. (Continental), a major oil producer, was CTAP’s largest customer, accounting for 60 percent of CTAP’s business out of its Bowman terminal. The Bowman terminal serviced Continental’s Buffalo District. Though J&J hauled almost exclusively out of the Bowman terminal, it rarely worked in the Buffalo District. During a blizzard in 2014, a Continental driver hit and killed two cows owned by Janvrin’s family. Janvrin called a local newspaper and gave comments complaining that drivers on nearby rural roads drove dangerously fast. Janvrin did not mention Continental or its drivers specifically. Hours after the newspaper published an article quoting Janvrin, a Continental employee complained to his superiors about Janvrin’s comments. A Continental director contacted CTAP and requested that J&J be banned from hauling equipment for Continental. In response, CTAP completely removed J&J from the Bowman terminal. Janvrin filed a tortious-interference lawsuit in state court against Continental, alleging that Continental persuaded CTAP to end its relationship with J&J in retaliation against Janvrin for his newspaper comments. Continental removed the case to federal court. At trial, the district court judge explained to the jury that Continental could refuse to do business with Janvrin but could not interfere with Janvrin’s business relationship with CTAP. The jury found in favor of Janvrin. Continental appealed, arguing that it merely requested to not do business with Janvrin, and that CTAP removed Janvrin from the Bowman terminal of its own accord.

Rule of Law

Issue

Holding and Reasoning (Wollman, J.)

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