C.H. Robinson Worldwide, Inc. v. Traffic Tech, Inc., No. 21-3259 (8th Cir. 2023)
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Employees at C.H. Robinson Worldwide, Inc. jumped ship to join Traffic Tech, Inc. C.H. Robinson then sued five of those former employees and Traffic Tech, raising various state-law claims, including tortious interference with a contractual relationship. After the case was removed to federal court, the district court granted summary judgment in favor of the former employees and Traffic Tech. The district court also awarded attorney fees to the former employees and Traffic Tech
The Eighth Circuit affirmed the district court’s dismissal of Plaintiff’s claim for tortious interference with prospective economic advantage, reversed the judgment in all other respects, and vacated the district court’s order awarding attorney fees and costs. The court held that Minnesota law applies to the interpretation and enforceability of Defendants’ employment contracts. The court remanded for the district court to consider whether C.H. Robinson’s claims or disputes against Peacock arose in California or elsewhere under Peacock’s employment contract. The court further remanded for the district court to substantively analyze whether all or part of the former employees’ contracts are unenforceable and, if not, whether the claims for breach of contract and tortious interference with a contractual relationship survive summary judgment.
Court Description: [Grasz, Author, with Loken and Gruender, Circuit Judges] Civil case - Employment contracts. Plaintiff sued five of its former employes and their new employer, alleging various state-law claims, including tortious interference with a contractual relationship. The district court erred in applying California law to interpret the employment contacts of four of the five individual defendants; with respect to the fifth defendant, the matter is remanded to the district court for it to determine whether plaintiff's claims against him arose in California or elsewhere under his employment contract; further, on remand the district court should substantively analyze whether all or part of the former employees' contracts are unenforceable and, if not, whether plaintiff's claims for breach of contract and tortious interference with a contractual relationship survive summary judgment; plaintiff has failed to address the basis for the district court's decision on plaintiff's claim for tortious interference with prospective economic advantage, and the court cannot conclude the district court erred in dismissing the claim; award of attorneys' fees and costs vacated.
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