Wal-Mart Stores, Inc. v. Sturges

Sturges (plaintiff) contracted to purchase a vacant lot located next to a Wal-Mart store. Sturges then entered into negotiations to lease the lot to Fleming Foods, a Texas grocery store chain. Wal-Mart Stores, Inc. (Wal-Mart) (defendant) then decided that it wanted to purchase the vacant lot in order to expand its existing store. Wal-Mart informed management at Fleming Foods that it wanted to purchase the lot and if it did not, it would relocate its existing store elsewhere. Fleming Foods then ended its negotiations with Sturges because it did not want to build a grocery store on the lot if it would not be next to a Wal-Mart store. Sturges brought suit against Wal-Mart for tortious interference with their prospective lease with Fleming Foods. The trial court judge first instructed the jury that Wal-Mart wrongfully interfered with Sturges’ prospective contractual arrangement with Fleming Foods if (1) there was a reasonable probability that Sturges would have entered into contractual relation, and (2) Wal-Mart intentionally prevented the contractual relation from occurring with the purpose of harming Sturges. The jury answered “yes” on the issue. The trial court next instructed the jury by asking whether Wal-Mart’s intentional interference was justified, namely, if Wal-Mart possessed an interest in the subject matter equal or superior to that of the other party, or if it results from the good faith exercise of a party’s rights, or the good faith exercise of a party’s mistaken belief of its rights. The jury answered “no” to the question. The jury found Wal-Mart liable and assessed $1 million in actual damages and $500,000 in punitive damages. The court of appeals affirmed the award of actual damages but remanded the matter to the trial court for a retrial on the issue of punitive damages. The Supreme Court of Texas granted Wal-Mart’s petition for review.