C.R. England v. Swift Transportation Co.Annotate this Case
The Supreme Court declined to overturn a rule established in St. Benedict’s Development Co. v. St. Benedict’s Hospital, 811 P.2d 194 (Utah 1991), in which the Court held that to prevail on a claim for intentional interference with contract the plaintiff must show that the defendant interfered through “improper means,” holding that “improper means” test remains a good rule.
Plaintiff filed suit against Defendant alleging that Defendant intentionally interfered with Plaintiff’s contracts with its employees. Defendant moved for summary judgment, arguing that Plaintiff failed to provide proof of “improper means” to support its claim. The federal district court concluded that there appears to be no clear, controlling Utah law regarding the interpretation of “improper means” and certified the question to the Supreme Court. The Supreme Court held (1) the element of improper means is firmly established in Utah law and rests upon a firm legal footing, and therefore, this Court declines to overturn St. Benedict’s; (2) the definition of “improper means” provided in Leigh Furniture & Carpet Co. v. Isom, 657 P.2d 293 (Utah 1982), and St. Benedict’s is reaffirmed; and (3) to prove the element of improper means based on an alleged violation of an established industry rule or standard the plaintiff must provide evidence of an objective, industry-wide standard.