Eldridge v. Johndrow

345 P.3d 553 (2015)

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Nature of the Case

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Facts

Eldridge (Ps) are the owners and operators of Harrison Companies, LLC, and Harrison Companies Property Management, LLC. Ps manage residential property and provide various other services for wealthy homeowners. Johndrow (D) is a former friend and client of Ps who used to recommend their services to his friends and other associates in the area. Lindsey Eldridge accused D of attacking her at a restaurant, and D accused Ps of spreading false rumors and stealing his mobile phone. D discovered various embarrassing facts about Ps: liens, a foreclosure, an old felony conviction, and unflattering news reports from before they moved to Utah. D threatened that if Ps refused to retract their accusations and compensate him for the allegedly stolen phone, he would have to protect his 'credibility' by revealing what he had found to the people to whom he had recommended. D emailed embarrassing information to 'at least nine' of Ps' institutional clients and communicated it verbally to a number of their individual clients. Ps sued D for tortious interference with economic relations, tortious interference with prospective economic relations, defamation, false light, and intentional infliction of emotional distress. In part, Ps alleged that D had interfered with their economic relations in pursuit of an improper purpose. D moved for summary judgment. The court granted summary judgment on the defamation and false light claims. Further, because the 'improper means' basis for tortious interference liability depended on D's alleged defamation, the court granted summary judgment on the tortious interference claims insofar as they were based on improper means. The court denied summary judgment on the tortious interference claims based on allegations of improper purpose. D argued that the court should follow the Restatement and hold that the communication of 'truthful information,' regardless of purpose, cannot constitute tortious interference. D appealed.