Gieseke v. IDCA, Inc.
844 N.W.2d 210
Minn.2014Background
- This case involves whether Minnesota recognizes a tort for interference with prospective economic advantage and the sufficiency of Diversified’s proof against IDCA.
- Diversified Water Diversion sued IDCA for, among other claims, tortious interference with prospective economic advantage after IDCA acted to disrupt Diversified’s business.
- An advisory jury awarded Diversified $220,000 for tortious interference and the district court entered judgment consistent with the jury.
- IDCA moved for judgment as a matter of law and for new trial/remittitur, arguing lack of recognition of the tort, lack of reasonable expectation, and excessive damages.
- IDCA allegedly interfered through actions including seizing Diversified’s equipment, changing Diversified’s address, settling a Diversified judgment against Standard for far less, and obtaining Diversified’s tax returns.
- The Fallon judgment against Art was later vacated as void; IDCA acquired Art’s Diversified interest at a sheriff’s sale, a fact relied upon by the parties and the court in assessing the case.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Minnesota recognizes tortious interference with prospective economic advantage | Diversified: recognized and viable claim under Minnesota law | IDCA: not recognized as a stand-alone Minnesota tort | Recognized as a viable claim with five elements |
| Proof of a reasonable expectation of economic advantage | Diversified had a prospective business relationship with identifiable third parties | Diversified failed to identify specific third parties | Diversified failed to identify a specific third party; insufficient proof |
| Damages and causation for the prospective economic advantage claim | Losses from IDCA’s interference caused future profits | Damages were speculative and not tied to identifiable prospective relationships | Damages not proven; damages theory failed |
| Whether the Fallon judgment and related interferences excuse liability | IDCA’s conduct caused the asserted interference post-Fallon | Fallon judgment void; no basis to excuse interference | Not reached/necessary due to failure on the preceding elements |
Key Cases Cited
- Witte Transportation Co. v. Murphy Motor Freight Lines, Inc., 291 Minn. 461 (Minn. 1971) (interference with noncontractual relationships recognized; need wrongful purpose)
- Wild v. Rarig, 302 Minn. 419 (Minn. 1975) (interference with prospective advantage; limitations and timing of claims)
- United Wild Rice, Inc. v. Nelson, 313 N.W.2d 628 (Minn. 1982) (elements of interference with prospective contractual relations; competition policy)
- Harbor Broadcasting, Inc. v. Boundary Waters Broadcasters, Inc., 636 N.W.2d 560 (Minn.App. 2001) (preemption discussion; not definitive on viability of the claim)
- Korea Supply Co. v. Lockheed Martin Corp., 29 Cal.4th 1134 (Cal. 2003) (recognition of factors for wrongful interference with prospective relations)