C.R. Eng. v. Swift Transp. Co., 437 P.3d 343

England (trucking company) hires and trains drivers under nine‑month exclusive employment agreements; it notifies competitors of those contracts.
Swift (competing trucking company) allegedly recruited England drivers still under contract by offering better pay/benefits.
England sued Swift for intentional interference with contract; Swift moved for summary judgment arguing England failed to prove the required element of "improper means."
Federal district court certified questions to the Utah Supreme Court about (1) whether "improper means" is an element of the tort for interference with existing contracts and (2) what constitutes "improper means."
Utah Supreme Court reviewed precedent (Bunnell, Leigh, St. Benedict’s, Eldridge) and considered whether to overrule St. Benedict’s, which extended Leigh’s improper‑means test to existing contracts.
Court declined to overrule St. Benedict’s and clarified that "improper means" requires conduct contrary to law or a violation of an objective, industry‑wide standard.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether "improper means" is an element of intentional interference with existing contracts	England: No; plaintiff need only prove intentional inducement and damages unless justified	Swift: Yes; Leigh and St. Benedict's require improper means as part of the prima facie case	Held: Yes; "improper means" is an element for interference with existing contracts and prospective relations; St. Benedict's reaffirmed
Whether St. Benedict's should be overruled	England: St. Benedict's misread Leigh and should be overturned under Eldridge factors	Swift: St. Benedict's correctly adopted a sound rule consistent with other jurisdictions	Held: Declined to overrule; precedent is well‑supported and firmly embedded in Utah law
What qualifies as "improper means"	England: Inducement of breach alone suffices as improper means	Swift: Requires conduct contrary to law or violation of an industry standard	Held: Improper means means conduct contrary to law (statute, regulation, recognized common‑law rule) or violation of an objective, industry‑wide standard or trade/professional rule
How to prove industry standard violation	England: (implicit) company rules or evidence of breach should suffice	Swift: Must be objective, industry‑wide standard	Held: Plaintiff must show an external, objective industry standard (e.g., expert testimony, uniform codes, industry regulations); internal company policy alone is insufficient

Bunnell v. Bills, 368 P.2d 597 (Utah 1962) (early Utah discussion that interference is not actionable when done by an act one has a legal right to do)
Leigh Furniture & Carpet Co. v. Isom, 657 P.2d 293 (Utah 1982) (articulated test requiring interference by improper means or purpose and listed examples of improper means)
St. Benedict's Development Co. v. St. Benedict's Hospital, 811 P.2d 194 (Utah 1991) (extended Leigh's improper‑means test to interference with existing contracts)
Eldridge v. Johndrow, 345 P.3d 553 (Utah 2015) (refined Leigh by eliminating "improper purpose" and articulated factors for overturning precedent)