Knight Enterprises, Inc. v. RPF Oil Co.
299 Mich. App. 275
Mich. Ct. App.2013Background
- Knight sues RPF for tortious interference with a contract, alleging RPF induced Saleh to breach Knight contracts.
- Saleh, who operated stations under Knight, later contracted with RPF to supply fuel for Port Huron and Roseville stations.
- Saleh had previously claimed no live Knight contracts and testified he would switch to RPF while Citgo stations were converted to Shell.
- Saleh sued Knight in April 2008 for breach; he then signed a ten-year fuel-supply agreement with RPF on May 20, 2008, effective July 1, 2008.
- During the transition, Knight continued delivering fuel to Saleh until Saleh switched; Knight later sued Saleh and recovered $275,000.
- At a July 2008 meeting, Fleckenstein discussed ethanol purchases; Knight confronted him with Knight’s contracts and disputed his recollection of Saleh’s contracts.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the claim is tortious interference with a contract | Knight | RPF | Knight failed to prove intentional instigation; claim fails |
Key Cases Cited
- Health Call of Detroit v Atrium Home & Health Care Servs, Inc, 268 Mich App 83 (Mich App 2005) (distinguishes contract vs. business-relationship interference)
- Badiee v Brighton Area Schools, 265 Mich App 343 (Mich App 2005) (elements of tortious interference with a contract; unjustified acts)
- Derderian v Genesys Health Care Sys, 263 Mich App 364 (Mich App 2004) (intentional wrongs and improper interference)
- CMI Int’l, Inc v Intermet Int’l Corp, 251 Mich App 125 (Mich App 2002) (unjustified acts and malice required for contract interference)
- Woody v Tamer, 158 Mich App 764 (Mich App 1987) (purpose to cause result required for liability)
- Trepel v Pontiac Osteopathic Hosp, 135 Mich App 361 (Mich App 1984) (proof of improper conduct and intent necessary)