Quelimane Co. v. Stewart Title Guaranty Co.
California Supreme Court
960 P.2d 513 (1998)
Quelimane Co. Western Land Bank (Western) and other property owners (collectively, the property owners) (plaintiffs) purchased real estate properties at tax sales. Western entered into a contract to sell to Robert Constant a parcel of property Western had acquired by tax deed. First American Title Insurance Co. (First American) (defendant) refused to issue a title-insurance policy unless Constant initiated a quiet-title action. As a result, Constant failed to complete payment for the property. The property owners brought an action against First American, Stewart Title Guaranty Co., and Placer Title Company (collectively, the insurance companies) (defendants), alleging, among other claims, intentional interference with contractual relations. The lower court dismissed the property owners’ claims for intentional interference with contractual relations. The court of appeal affirmed, holding that the complaint failed to state a claim for interference with contractual relations because it lacked allegations that the insurance companies’ conduct was wrongful for any reason other than the refusal to issue title-insurance policies. The property owners appealed.
Rule of Law
Holding and Reasoning (Baxter, J.)
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