Redfearn v. Trader Joe’s Co.
California Court of Appeal
20 Cal. App. 5th 989 (2018)
Wayne Redfearn (plaintiff) was the largest shareholder of food broker Caliber Sales and Marketing Corporation (Caliber). Caliber represented Seneca Foods Corporation (Seneca) and Sunsweet Growers Inc. (Sunsweet) and placed their products in stores operated by Trader Joe’s Company (defendant). In or around 2014, Trader Joe’s executives allegedly told Seneca and Sunsweet representatives that Redfearn was spreading rumors that the only way to do business with Trader Joe’s was to pay bribes demanded by Trader Joe’s employees. According to Redfearn, those accusations were false and defamatory and were intended to convince Seneca and Sunsweet to terminate their relationships with Caliber. Seneca and Sunsweet ultimately terminated their contracts with Caliber with respect to supplying their products to Trader Joe’s. Redfearn sued Trader Joe’s in California state court, alleging claims including intentional interference with contractual relations and intentional and negligent interference with prospective economic advantage. Trader Joe’s demurred to the complaint, asserting that only a stranger to a contract could be liable for interference with contractual relations and interference with prospective economic advantage. Trader Joe’s contended that it was not a stranger and thus could not be held liable, because performance of Caliber’s contracts with Seneca and Sunsweet depended on whether Trader Joe’s purchased Seneca’s and Sunsweet’s products. The trial court sustained the demurrer, agreeing that Trader Joe’s was not a stranger to the contracts and finding that Redfearn had not alleged any independently wrongful conduct by Trader Joe’s, as required to maintain causes of action for intentional or negligent interference with prospective economic advantage. Redfearn appealed.
Rule of Law
Holding and Reasoning (Perluss, C.J.)
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