CRST Expedited, Inc. v. Transam Trucking, Inc., No. 18-2633 (8th Cir. 2020)
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CRST filed suit against TransAm, alleging that TransAm wrongfully recruited and hired several long-haul truck drivers who were under contract with CRST. The district court granted TransAm's motion for summary judgment and dismissed all of CRST's claims with prejudice.
The Eighth Circuit held that the district court erred with respect to the causation element but did not err with respect to the existence of a valid contract element, and that the record contains sufficient evidence to support the intentional and improper interference element. The court also held that the district court erred in granting TransAm's motion for summary judgment on CRST's unjust enrichment claim. Finally, the court held that the district court did not abuse its discretion in finding the drivers were not indispensable parties. Accordingly, the court reversed and remanded the district court's order granting TransAm's motion for summary judgment and affirmed the district court's determination that the drivers are not indispensable parties to the proceedings.
Court Description: [Shepherd, Author, with Loken and Stras, Circuit Judges] Civil case - Intentional Interference with Contracts. In this action CRST alleged TransAm intentionally interfered with CRST's employment contracts with 167 drivers it had trained as part of an employment program; the district court erred in granting TransAm's motion for summary judgment on CRST's claim for intentional interference with contract as CRST provided sufficient evidence to create a genuine issue of material fact on all three elements of the claim - a valid contract with the drivers; TransAm's knowledge of the contract and that TransAm's actions caused the drivers not to perform their contracts with CRST; non-compete clause in the drivers' contract was not void ab initio under Iowa law; the district court also erred in granting TransAm's motion for summary judgment on CRST's unjust enrichment claim, as there was sufficient evidence that a benefit was conferred on TransAm at CRST's expense and that it would be unfair for TransAm to retain the alleged benefit; on TransAm's cross-appeal arguing the case should have been dismissed because CRST failed to join indispensable parties - the 167 drivers - under Rule 19(b), the district court did not abuse its discretion in determining the drivers were not indispensable. Judge Stras, dissenting.
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