Janvrin v. Continental Resources, Inc.

934 F.3d 845 (8th Cir. 2019)

Facts

In 2010 P organized J&J Trucking to haul materials for oil equipment suppliers on an as-needed basis. Roughly 96% of J&J's income came from CTAP, an equipment supplier. P employed others to drive the trucks for J&J Trucking. Most of those he hired, some 29 in total, were local ranchers, attesting to their reliability and punctuality in meeting their schedules. D was CTAP's largest customer in that region. It accounted for roughly 60% of CTAP's business from the Bowman terminal. Although P's company hauled almost exclusively out of the Bowman terminal, less than 1% of P's work for CTAP involved hauling to the Buffalo District. During a February 2014 blizzard, a D pick-up truck driver struck and killed two cows belonging to P's relatives. The relatives contacted the local newspaper. P also called the local newspaper, which published an article about the cow-truck collision and paraphrased P's remarks about driving too fast for rural conditions. Though Janvrin's comments made no mention of D or its drivers, Carlson who supervises this district from D's field office read the article and thought P was 'biting the hand that feeds him' by 'pointing the finger at D as the cause of the accident.' Carlson contacted his superiors to request that P no longer haul materials to D's Buffalo District sites. D's Director Anderson called Michael 'Stoney' McCarrell, Senior Vice-President of Operations at CTAP's headquarters in Lafayette, Colorado. P was informed that he had been removed from the Bowman terminal lineup. P received the call on the evening of February 19, 2014, hours after his published remarks in the local newspaper had been distributed. A week later a D employee told one of P's truckers-a former D employee-that he had overheard Carlson bragging that he had shut down a trucking firm. P filed a tortious interference claim. The case proceeded to trial, at which the district court instructed the jury that D had the right to refuse to do business with P, but that it could not interfere with P and CTAP's business relationship. The jury returned a verdict for P awarding him $123,669 in compensatory damages and $123,669 in punitive damages. D appealed.