Rite Aid Corp. v. Lake Shore Investors

471 A.2d 735 (1984)

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Nature of the Case

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Facts

The claim of injurious falsehood arose from D's representations that a valid lease agreement on certain property existed between it and P. The claim of wrongful interference with a contract arose from the cancellation by BTR Realty, Inc. of an agreement whereby it was to purchase certain property from P. D claimed that a portion of this property was subject to its alleged lease with P. BTR Realty, Inc. insisted on a clause in the purchase agreement to the effect that it could withdraw from the agreement if P did not furnish a written release from D. When the release was not forthcoming, BTR Realty, Inc. withdrew from the contract. P sued D for two causes of action. In the case at hand the parties, at trial, and before the intermediate appellate court made no distinction between the two torts, injurious falsehood (sometimes known as disparagement or slander of title) and wrongful interference with contractual relations, with respect to the measure of damages. Apparently, they proceeded on the assumption that liability for damages under each tort was measured by the same test. The trial court offered benefit of the bargain as the measure of damages. The trial court refused to admit evidence of damages measured under a tort standard. The Court of Special Appeals believed that the trial court erred in limiting the evidence of damages to the `benefit of bargain.' It held that P should have been permitted to prove such damages as would reasonably flow from the tortious, contractual interference by D. It reversed the judgment in favor of D and remanded the case for a new trial. D appealed.