Eldridge v. Johndrow
2015 UT 21
| Utah | 2015Background
- Joseph and Lindsey Eldridge (through Harrison Companies LLCs) sued David Johndrow for, among other claims, tortious interference with economic and prospective economic relations based on Johndrow’s dissemination of embarrassing but substantially true information to the Eldridges’ clients.
- The district court granted summary judgment to Johndrow on defamation and false light, concluding the communications were substantially true, and thus granted summary judgment on tortious-interference claims premised on improper means.
- The district court denied summary judgment as to tortious-interference claims based solely on an alleged improper purpose (motivation), relying on Utah precedent allowing such claims.
- Johndrow appealed the denial; the Utah Supreme Court considered whether the court should retain the improper-purpose basis for tortious-interference liability.
- The Supreme Court concluded improper-purpose liability (liability based only on motive where means are lawful) is unworkable, conflicts with notice and free-speech concerns, and should be abandoned; tortious-interference claims must allege improper means.
- The Court reversed the denial of summary judgment and remanded, holding the Eldridges failed to present evidence of improper means.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether an improper purpose alone (without improper means) can support a tortious-interference claim | The Eldridges argued tortious interference may be shown if defendant acted with an improper purpose predominate over legitimate motives | Johndrow argued truthful communications cannot be tortious interference regardless of purpose and urged rejection of motive-based liability | The court held improper purpose alone is insufficient; liability requires proof of improper means |
| Whether reconsideration of prior Utah precedent (allowing improper-purpose claims) was appropriate | Eldridges urged stare decisis—prior holdings required denial of summary judgment | Johndrow sought overruling or restriction of the doctrine, citing weak authority, poor guidance, and chilling effects | The court found stare decisis inapplicable and permitted reconsideration, overruling prior dicta and Pratt to the extent they allowed motive-only liability |
| Whether the alleged communications were defamatory and could constitute improper means | Eldridges relied on the substance of the communications to show tortious interference by improper means | Johndrow showed the communications were "at least substantially true," arguing they were not defamatory or wrongful means | The district court’s determination that communications were substantially true was upheld as to defamation; plaintiffs failed to show improper means for tortious-interference claims |
| Remedy/posture: Whether denial of summary judgment should stand | Eldridges argued genuine issues of fact on improper purpose justified denial | Johndrow argued no triable issue on improper means and sought reversal | The Supreme Court reversed the denial of summary judgment because plaintiffs lacked evidence of improper means |
Key Cases Cited
- Leigh Furniture & Carpet Co. v. Isom, 657 P.2d 293 (Utah 1982) (adopted improper-purpose language but did not rest its decision on that ground)
- Pratt v. Prodata, Inc., 885 P.2d 786 (Utah 1994) (upheld jury verdict based on improper purpose; court overruled to the extent it allowed motive-only liability)
- ProMax Development Corp. v. Mattson, 943 P.2d 247 (Utah Ct. App. 1997) (court of appeals affirmed finding of improper purpose in a fact-specific context)
- Wal-Mart Stores, Inc. v. Sturges, 52 S.W.3d 711 (Tex. 2001) (rejected motive-only tortious-interference liability; held wrongful conduct is required)