Realauction.Com, LLC v. Grant Street Group, Inc., 82 So. 3d 1056

Grant Street sues Realauction and McClendon for defamation and tortious interference with a Broward County contract; trial court directed verdict on all counts except a 2006 tortious interference claim; appellate court reverses the 2005 claim and remands; evidence showed the 2005 decision to terminate negotiations preceded Realauction’s email and there was no causative link established; no stay of 2006 claim because the 2005 email did not exist in the context of a surviving 2006 relationship; Grant Street’s evidence relied on speculative testimony and failed to prove a probable contract would have been executed absent the email.
Background continued (concise clarifier)
The 2005 email from Realauction alleged Grant Street’s involvement in lawsuits and potential inquiries by the State Attorney General’s Office, which Broward County linked to terminating negotiations; the 2006 negotiations proceeded but Grant Street was not awarded the contract.
Background (procedural posture)
The appellate court reviews for competent substantial evidence and stages the analysis by first addressing the 2005 claim before the 2006 claim.
Background (outcome)
Court reverses the final judgment as to the 2005 tortious interference counts and the 2006 claim, directs entry of final judgment for Realauction, and vacates the related cost judgment.
Background (law on damages)
Damages issues raised by Realauction become moot due to resolution of the 2005 claim and the reversal of the final judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the 2005 tortious interference claim supported by competent substantial evidence?	Grant Street contends the email caused termination.	Realauction argues termination was independent of the email.	Yes; court directed verdict for Realauction on 2005 claim.
Did Grant Street prove existence of a probative relationship with the County in 2005 so as to support interference?	Grant Street asserts an identifiable expectation existed.	Defendant contends no enforceable or probable contract existed.	No; inception of the relationship was not established.
Can the 2006 claim survive given the 2005 email and timing of the relationship?	Interference affected the 2006 relationship.	No relationship existed when interference occurred.	Failing on causation and timing; 2006 claim fails as a matter of law.

Salit v. Ruden, McClosky, Smith, Schuster & Russell, P.A., 742 So.2d 381 (Fla. 4th DCA 1999) (elements of tortious interference with a business relationship)
Ethan Allen, Inc. v. Georgetown Manor, Inc., 647 So.2d 812 (Fla. 1994) (relationship evidenced by actual and identifiable understanding)
St. Johns River Water Mgmt. Dist. v. Femberg Geological Servs., Inc., 784 So.2d 500 (Fla. 5th DCA 2001) (when evaluating causation, consider whether the contract would have been entered absent interference)
ISS Cleaning Seros. Group, Inc. v. Cosby, 745 So.2d 460 (Fla. 4th DCA 1999) (reversing denial of directed verdict where no competent substantial evidence of an agreement would have been completed)
Douglass Fertilizers & Chem., Inc. v. McClung Landscaping, Inc., 459 So.2d 335 (Fla. 5th DCA 1984) (loss of future business too speculative to support a verdict)
Kam Seafood Co. v. State, 496 So.2d 219 (Fla. 1st DCA 1986) (reversing based on unreasonable inference contrary to direct evidence)
Bernstein v. True, 636 So.2d 1364 (Fla. 4th DCA 1994) (existence of a relationship at time of interference required)
Rockledge Mall Assocs., Ltd. v. Custom Fences of S. Brevard, Inc., 779 So.2d 554 (Fla. 5th DCA 2001) (reversing on causation where only speculative evidence linked interference)