Ride PDX v. Tee & B, LLC, 519 P.3d 870

Plaintiffs Ride PDX (indoor cycling studio) and defendants Growler Guys (growler bar) leased adjacent commercial spaces; defendants' lease included a quiet-enjoyment clause.
After Ride PDX opened, defendants repeatedly complained to the landlord (Riva/Greystar) about bass, vibrations, and instructor voices penetrating the shared wall and said the noise harmed their business.
Defendants’ counsel sent a demand letter threatening litigation if the landlord did not remediate; Riva then pursued eviction proceedings against Ride PDX, which Ride PDX successfully defended at bench trial.
Ride PDX sued defendants for intentional interference with economic relations, alleging defendants used deceit/misrepresentation to induce Riva’s adverse action.
The trial court granted summary judgment to defendants, finding no wrongful conduct because defendants were enforcing their contractual quiet-enjoyment right; Ride PDX appealed.
The court of appeals reversed and remanded: enforcing a valid contract negates an improper-purpose theory as a matter of law, but material disputes about misrepresentations can create a triable issue on improper means.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether defendants acted for an improper purpose when they complained and threatened suit	Defendants' real purpose was to extract rent concessions and to injure Ride PDX’s relationship with the landlord	Defendants were enforcing an express contractual right (quiet enjoyment), so their purpose was legitimate	Enforcement of a valid contract is a legitimate purpose as a matter of law; plaintiffs failed to raise a fact issue on improper purpose
Whether defendants used improper means (misrepresentation) in enforcing the lease	Defendants made false or exaggerated statements to Riva about the nature/extent of noise and its financial effects, constituting deceit	Complaints reflected actual noise impacts (customer complaints, lost business), so statements were accurate and privileged as contract enforcement	Even when enforcing a contract, use of improper means (e.g., actionable misrepresentations) can remove the privilege; the record presented enough conflicting evidence about the truth of defendants’ statements to create a jury question

Uptown Heights Associates v. Seafirst Corp., 320 Or 638 (defendant invoking express contractual remedy has a legitimate purpose; enforcement alone does not create liability)
Top Service Body Shop v. Allstate Ins. Co., 283 Or 201 (even legitimate objectives can be unlawful if achieved by improper means; improper means includes deceit/misrepresentation)
Northwest Natural Gas Co. v. Chase Gardens, Inc., 328 Or 487 (to show improper purpose, actor must intend to inflict injury on the plaintiff)
Bernard v. S.B., Inc., 270 Or App 710 (enforcing a valid contract is not wrongful as a matter of law; trial issues remain if contract is void or other improper means are alleged)
Allen v. Hall, 328 Or 276 (elements required to prove intentional interference with economic relations)
Douglas Medical Center v. Mercy Medical Center, 203 Or App 619 (improper means must be independently wrongful and include misrepresentation; tort elements need not mirror the underlying tort fully)