West Plains, LLC v. Retzlaff Grain Co. Inc., No. 16-2650 (8th Cir. 2017)
Annotate this CaseAfter ten individuals resigned from West Plains to join a start-up freight brokerage operation founded by the former owner of West Plains, West Plains filed suit. The jury found defendants liable for tortious interference with business relationships and breach of the duty of loyalty. The Eighth Circuit affirmed, holding that, based on the nature and intent of their actions, a jury could reasonably find the employee defendants committed unjust acts of interference; the evidence was sufficient to show defendants' actions caused a loss of profits to West Plains, and that the loss continued after the expiration of the temporary injunction; there was sufficient evidence for a reasonable jury to find the employee defendants breached their duty of loyalty; given the extent to which each employee defendant was involved in the planning of the start up and the time in which they were so committed, there was adequate support for each forfeiture award; and there was abundant evidence showing defendants entered into an agreement tortiously to interfere with West Plains' business or to breach their duty of loyalty. Finally, the court affirmed the district court's denial of defendants' motion for a new trial or altered or amended judgment.
Court Description: Riley, Author, with Beam and Shepherd, Circuit Judges] Civil case - Torts. A jury could find defendant Wells unjustly interfered with plaintiff's business relationships by knowingly paying, recruiting and seizing plaintiff's workforce, infrastructure and customer relationships; there was also sufficient evidence to support the jury's findings of unjust acts of interference by other defendants, former employees who secretly took with them customer lists and other confidential information for the immediate benefit of their new employer; the evidence was sufficient to show defendants' actions caused a loss of profits to plaintiff and that the loss continued after the expiration of the district court's two-month long temporary injunction; there was sufficient evidence for a reasonable jury to find defendants breached their duty of loyalty under Nebraska law; forfeiture awards upheld; there was abundant evidence to show defendants entered into an agreement tortiously to interfere with plaintiff's business or breach their duty of loyalty; lost profits award affirmed; no error in admitting evidence from plaintiff's expert concerning the value of the business at the time the employees left; the jury instructions on damages were not plainly erroneous; compensatory damage award affirmed; the evidence was sufficient to show plaintiff attempted to mitigate its damages after the defections.
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