Utah Supreme Court Drops "Improper Purpose" as a Viable Method of Proving Intentional Interference with Prospective Economic Relations Claims
In a very important decision issued yesterday, the Utah Supreme Court in Eldridge v. Johndrow , 2015 UT 21, abandoned the "improper purpose" avenue of proving intentional interference with prospective economic relations claims. Despite recognizing that proof of interference for an improper purpose has been the law since the Court's decision more than 30 years ago in Leigh Furniture & Carpet Co.v. Isom , 657 P.2d 293, 307 (Utah 1982), the Court side-stepped its prior precedent, referenced the risks inherent in proving motive or purpose and the potential for causing juries to find liability too easily for "legitimate commercial activity" to justify its reversal. The Court further noted that despite its attempt to circumscribe the doctrine by allowing improper-purpose liability only where “the improper purpose predominate[s]” and by counseling that it would usually be “prudent” not to apply the doctrine to “commercial conduct," such attempts had been ...