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8 California opinions name it 2 courts 1997–2023 3 in the last five years
The cases below were cited by California courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Korea Supply Co. v. Lockheed Martin Corp.green2 sentences2021(Korea Supply, supra, 29 Cal.4th at p. 1159 [“It is this independent wrongfulness requirement that makes defendants’ interference with plaintiff’s business expectancy a tortious act”].) There is a good reason for this. 2021(Korea Supply, supra, 29 Cal.4th at p. 1159 [“It is this independent wrongfulness requirement that makes defendants’ interference with plaintiff’s business expectancy a tortious act”].) There is a good reason for this. | 3 | 4 |
Della Penna v. Toyota Motor Sales, USA, Inc.green2 sentences2020Opinion of the Court by Liu, J. free to leave.” (Id. at p. 1151; see also id. at p. 1145 [observing that the independent wrongfulness requirement “will promote the public policies supporting the right of at-will employees to pursue opportunities for economic betterment and the right of employers to compete for talented workers”].) Second, we reasoned that “the economic relationship between parties to contracts that are terminable at will is distinguishable from the relationship between parties to other legally binding contracts.” (Reeves, supra, 33 Cal.4th at p. 1151 .) We explained that inter 2020The purpose of the independent wrongfulness requirement in economic interference torts is to “balance between providing a remedy for predatory economic behavior and keeping legitimate business competition outside litigative bounds.” (Della Penna, supra, 11 Cal.4th at p. 378 ; see Buckaloo, supra, 14 Cal.3d at p. 828 ; Imperial Ice, supra, 18 Cal.2d at p. 36 .) Where economic relationships have solidified into binding future promises, the stability of the contractual relationship takes precedence over business competition. | 2 | 4 |
Buckaloo v. Johnsongreen2 sentences2020The purpose of the independent wrongfulness requirement in economic interference torts is to “balance between providing a remedy for predatory economic behavior and keeping legitimate business competition outside litigative bounds.” (Della Penna, supra, 11 Cal.4th at p. 378 ; see Buckaloo, supra, 14 Cal.3d at p. 828 ; Imperial Ice, supra, 18 Cal.2d at p. 36 .) Where economic relationships have solidified into binding future promises, the stability of the contractual relationship takes precedence over business competition. 2020The purpose of the independent wrongfulness requirement in economic interference torts is to “balance between providing a remedy for predatory economic behavior and keeping legitimate business competition outside litigative bounds.” (Della Penna, supra, 11 Cal.4th at p. 378 ; see Buckaloo, supra, 14 Cal.3d at p. 828 ; Imperial Ice, supra, 18 Cal.2d at p. 36 .) Where economic relationships have solidified into binding future promises, the stability of the contractual relationship takes precedence over business competition. | 1 | 2 |
Reeves v. Hanlongreen1 sentence2020Opinion of the Court by Liu, J. free to leave.” (Id. at p. 1151; see also id. at p. 1145 [observing that the independent wrongfulness requirement “will promote the public policies supporting the right of at-will employees to pursue opportunities for economic betterment and the right of employers to compete for talented workers”].) Second, we reasoned that “the economic relationship between parties to contracts that are terminable at will is distinguishable from the relationship between parties to other legally binding contracts.” (Reeves, supra, 33 Cal.4th at p. 1151 .) We explained that inter | 1 | 1 |
Exxon Corp. v. Superior Courtgreen2 sentences2005(Marin Tug, supra, at p. 832.) Among the decisions it cited for that proposition were Della Pena, supra, at pages 391 to 392, which concerned only the independent wrongfulness requirement, Hamro v. Shell Oil Co. (9th Cir. 1982) 674 F.2d 784, 790 , which considered whether Shell Oil’s alleged contractual interference in the affairs of a company in which Shell held a financial interest was privileged, and Exxon Corp. v. Superior Court (1997) 51 Cal.App.4th 1672, 1688 [ 60 Cal.Rptr.2d 195 ], which was also concerned solely with the independent wrongfulness requirement. 2005(Marin Tug, supra, at p. 832.) Among the decisions it cited for that proposition were Della Pena, supra, at pages 391 to 392, which concerned only the independent wrongfulness requirement, Hamro v. Shell Oil Co. (9th Cir. 1982) 674 F.2d 784, 790 , which considered whether Shell Oil’s alleged contractual interference in the affairs of a company in which Shell held a financial interest was privileged, and Exxon Corp. v. Superior Court (1997) 51 Cal.App.4th 1672, 1688 [ 60 Cal.Rptr.2d 195 ], which was also concerned solely with the independent wrongfulness requirement. | 1 | 1 |
Youst v. Longogreen2 sentences2004(Joust v. Longo (1987) 43 Cal.3d 64, 71, fn. 6 [ 233 Cal.Rptr. 294 , 729 P.2d 728 ].) 7 Because the wrongful conduct in this case pertains only to the termination of at-will contracts, we need not and do not express an opinion whether an independent wrongfulness requirement would be appropriate for cases in which a defendant allegedly induces the breach of an otherwise enforceable term of an at-will contract. 8 It may be inferred from the facts of GAB and the authority to which GAB cites (Bancroft-Whitney Co. v. Glen (1966) 64 Cal.2d 327 [ 49 Cal.Rptr. 825 , 411 P.2d 921 ]) that the “tort of u 2004(Joust v. Longo (1987) 43 Cal.3d 64, 71, fn. 6 [ 233 Cal.Rptr. 294 , 729 P.2d 728 ].) 7 Because the wrongful conduct in this case pertains only to the termination of at-will contracts, we need not and do not express an opinion whether an independent wrongfulness requirement would be appropriate for cases in which a defendant allegedly induces the breach of an otherwise enforceable term of an at-will contract. 8 It may be inferred from the facts of GAB and the authority to which GAB cites (Bancroft-Whitney Co. v. Glen (1966) 64 Cal.2d 327 [ 49 Cal.Rptr. 825 , 411 P.2d 921 ]) that the “tort of u | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in California. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Quelimane Co. v. Stewart Title Guaranty Co.
green
2 sentences2021Where the economic relationship between a plaintiff and a third party has ripened into an enforceable contract, that “contract receives greater solicitude” and a defendant’s effort to cause a breach of that contract “is . . . a wrong in and of itself.” (Quelimane Co. v. Stewart Title Guaranty Co. (1998) 19 Cal.4th 26, 55-56 .) But where the plaintiff and a third party have only a “prospective contractual relationship,” that third party’s business is still up for grabs: “[A]s long as” other market participants “use[] fair and 11 reasonable means” to entice the third party away from the plaintif 2020A plaintiff states a claim so long as it alleges that the defendant knew interference was “ ‘certain or substantially certain to occur as a result of [defendant’s] action.’ ” (Quelimane, supra, 19 Cal.4th at p. 56 .) Without an independent wrongfulness requirement, a competitor’s good faith offer that causes a business to withdraw from an at-will contract could trigger liability or at least subject the competitor to costly litigation. | 3 | 2020–2021 |
Ixchel Pharma, LLC v. Biogen, Inc.
green
2 sentences2023In both, the vendor has no legal assurance of the buyer’s continued purchases.” (Ixchel, supra, 9 Cal.5th at p. 1147 .) Second, “allowing interference with at-will contract claims without requiring independent wrongfulness risks chilling legitimate business competition.” (Ixchel, supra, 9 Cal.5th at p. 1148 .) “Without an independent wrongfulness requirement, a competitor’s good faith offer that causes a business to withdraw from an at-will contract could trigger liability or at least subject the competitor to costly litigation. 2023In both, the vendor has no legal assurance of the buyer’s continued purchases.” (Ixchel, supra, 9 Cal.5th at p. 1147 .) Second, “allowing interference with at-will contract claims without requiring independent wrongfulness risks chilling legitimate business competition.” (Ixchel, supra, 9 Cal.5th at p. 1148 .) “Without an independent wrongfulness requirement, a competitor’s good faith offer that causes a business to withdraw from an at-will contract could trigger liability or at least subject the competitor to costly litigation. | 1 | 2023–2023 |
Imperial Ice Co. v. Rossier
green
1 sentence2020The purpose of the independent wrongfulness requirement in economic interference torts is to “balance between providing a remedy for predatory economic behavior and keeping legitimate business competition outside litigative bounds.” (Della Penna, supra, 11 Cal.4th at p. 378 ; see Buckaloo, supra, 14 Cal.3d at p. 828 ; Imperial Ice, supra, 18 Cal.2d at p. 36 .) Where economic relationships have solidified into binding future promises, the stability of the contractual relationship takes precedence over business competition. | 1 | 2020–2020 |
Bob Hamro v. Shell Oil Co.
green
1 sentence2005(Marin Tug, supra, at p. 832.) Among the decisions it cited for that proposition were Della Pena, supra, at pages 391 to 392, which concerned only the independent wrongfulness requirement, Hamro v. Shell Oil Co. (9th Cir. 1982) 674 F.2d 784, 790 , which considered whether Shell Oil’s alleged contractual interference in the affairs of a company in which Shell held a financial interest was privileged, and Exxon Corp. v. Superior Court (1997) 51 Cal.App.4th 1672, 1688 [ 60 Cal.Rptr.2d 195 ], which was also concerned solely with the independent wrongfulness requirement. | 1 | 2005–2005 |
Bancroft-Whitney Co. v. Glen
green
2 sentences2004(Joust v. Longo (1987) 43 Cal.3d 64, 71, fn. 6 [ 233 Cal.Rptr. 294 , 729 P.2d 728 ].) 7 Because the wrongful conduct in this case pertains only to the termination of at-will contracts, we need not and do not express an opinion whether an independent wrongfulness requirement would be appropriate for cases in which a defendant allegedly induces the breach of an otherwise enforceable term of an at-will contract. 8 It may be inferred from the facts of GAB and the authority to which GAB cites (Bancroft-Whitney Co. v. Glen (1966) 64 Cal.2d 327 [ 49 Cal.Rptr. 825 , 411 P.2d 921 ]) that the “tort of u 2004(Joust v. Longo (1987) 43 Cal.3d 64, 71, fn. 6 [ 233 Cal.Rptr. 294 , 729 P.2d 728 ].) 7 Because the wrongful conduct in this case pertains only to the termination of at-will contracts, we need not and do not express an opinion whether an independent wrongfulness requirement would be appropriate for cases in which a defendant allegedly induces the breach of an otherwise enforceable term of an at-will contract. 8 It may be inferred from the facts of GAB and the authority to which GAB cites (Bancroft-Whitney Co. v. Glen (1966) 64 Cal.2d 327 [ 49 Cal.Rptr. 825 , 411 P.2d 921 ]) that the “tort of u | 1 | 2004–2004 |
GAB Business Services, Inc. v. Lindsey & Newsom Claim Services, Inc.
green
1 sentence2004(GAB, supra, 83 Cal.App.4th at p. 425 ; Bancroft-Whitney Co. v. Glen, supra, 64 Cal.2d at pp. 352-353.) 9 Prior to defendants’ departure, plaintiffs’ firm went by the name of “Reeves and Hanlon, Professional Law Corporation.” The business announcement defendants mailed out informed plaintiffs’ clients of the formation of “Hanlon & Greene, A Professional Corporation,” but made no mention of Robert Reeves’s continuing practice. | 1 | 2004–2004 |
Marin Tug & Barge, Inc. v. Westport Petroleum, Inc.
green
1 sentence2003(Marin Tug & Barge v. Westport Petroleum (9th Cir. 2001) 271 F.3d 825 , 832.) We conclude, therefore, that an act is independently wrongful if it is unlawful, that is, if it is proscribed by some constitutional, statutory, regulatory, common law, or other determinable legal standard. 11 (See Marin Tug & Barge, supra, at p. 835; see also Della Penna, supra, 11 Cal.4th at p. 408 (conc. opn. of Mosk, J.) [“It follows that the tort may be satisfied by intentional interference with prospective economic advantage by independently tortious means”].) Here, KSC has clearly satisfied the independent wro | 1 | 2003–2003 |
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.