Parrott v. Jones
2014 Ohio 3220
Ohio Ct. App.2014Background
- Parrott sued Jones for intentional interference with business relationships, claiming lost income from 2005–2008 due to an allegedly defamatory email and related communications.
- Parrott and Ursitz formed a joint venture in 1999 for the Scrape Wiz product; Jones invested 150,000 for 10% in 2000.
- Jones’s communications in 2005 targeted Parrott’s business associates; Parrott alleged these stopped collaborations and caused income loss.
- Jones faced earlier related litigation (2003 Guernsey County suit) involving fiduciary duties, spoliation, and conspiracy that was ultimately dismissed.
- Parrott’s 2009 Lacey Act conviction affected credibility and purported business relationships, with trial concluding in Jones’s favor on damages.
- The trial court found Parrott failed to prove a prospective relationship, intentional interference, and damages by a preponderance of the evidence; judgment for Jones affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Parrott proved the elements of intentional interference with a business relationship | Parrott argues Jones’s emails/communications damaged business relationships | Jones contends no proven prospective relationship or causation | Parrott did not prove all elements; judgment affirmed |
| Whether Parrott proved financial damages from Jones’s interference | Parrott asserts lost income from speaking engagements | Jones argues evidence failed to show actual damages | Damages not proven by preponderance; judgment affirmed |
Key Cases Cited
- Eastley v. Volkman, 132 Ohio St.3d 328 (2012) (established manifest-weight standard in civil cases)
- SST Bearing Corp. v. Twin City Fan Companies, Ltd., 2012-Ohio-2490 (1st Dist. Hamilton) (applies manifest-weight standard in civil review)
- Morrison v. Renner, 2011-Ohio-6780 (5th Dist. Muskingum) (elements of interference with business relationship)
- Gen. Medicine, P.C. v. Morning View Care Ctr., 2004-Ohio-4669 (5th Dist. Tuscarawas) (elements and damages in tort interference)
- A&B–Abell Elevator Co. v. Columbus/Cent. Ohio Bldg. & Constr. Trades Council, 73 Ohio St.3d 1 (1995) (definition of tortious interference with business relations)
- Seasons Coal Co. v. Cleveland, 10 Ohio St.3d 77 (1984) (weight-of-the-evidence standard in civil appeals)
- State v. Thompkins, 78 Ohio St.3d 380 (1997) (criminal standard adopted for civil manifest-weight review)