WILLIAM F. YODER, APPELLANT,
v.
SHELL OIL COMPANY, APPELLEE
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William Yoder, a Shell Oil dealer, sued Shell Oil for intentional interference with his contract to sell his dealership to American Way Enterprises. The trial court instructed the jury using an overly broad privilege standard that allowed interference based on any financial interest, and the jury found for Shell Oil. The appellate court reversed, holding that the privilege to interfere with a contract requires a financial interest in the nature of an investment and does not permit purposeful causing of breach.
The trial court's jury instruction was erroneous because it was not limited to financial interests in the nature of an investment and because it did not exclude the privilege of purposefully causing a breach of contract. The privilege to interfere with a contract based on financial interest is not unlimited and does not extend to purposeful causing of breach.
[1] A privilege to interfere with a third party's contract based on a financial interest is not unlimited.
[2] To justify interference with a contract due to a financial interest, the interfering party must have a financial interest in the third party's business that is in the nat…
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Join FLexlaw to unlock all legal intelligence“it is clear that the privilege to interfere in a contract because of a financial interest is not unlimited”
Establishes the fundamental principle that financial interest does not provide blanket privilege to interfere with contracts
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Join FLexlaw to unlock all legal intelligenceYoder, a Shell Oil dealer, decided to sell his dealership to American Way Enterprises, which Shell had previously approved. A Shell employee told Amer…
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RYDER, Judge.
This appeal deals with the tort of intentional interference with a contract. William Yoder, a Shell Oil dealer, claimed damages from Shell Oil Company for wrongful interference with a contract for the sale of his dealership to American Way Enterprises, Inc. At trial, Yoder testified that he had decided to sell his Shell dealership and entered into a contract of sale with American Way whom Shell Oil had previously approved. Thereafter, according to Yoder, an employee of Shell Oil told American Way that it was paying too much for the purchase of the business. As a result, American Way did not go ahead with the contract.
Over Yoder’s objection, the court gave a jury instruction on the privilege to interfere based upon the “Prosser”1 test of privilege. The instruction read in part:
You should find that defendant’s actions were privileged if you find that the defendant had a present existing economic interest of its own to protect, such as the ownership or condition of property, or a prior contract of its own, or financial interest in the affairs of the person persuaded or who caused the breach.
The jury returned a verdict for Shell Oil upon which the court entered judgment. Yoder appeals, and among other things, he challenges the validity of the instruction set out above.
The area of the law dealing with interferences with a contract has not settled into a set of definite rules. However, it is clear that the privilege to interfere in a contract because of a financial interest is not unlimited. Frank Coulson, Inc.-Buick v. General Motors Corp., 488 F. 2d 202 (5th Cir. 1974). The better view is that it is necessary for the interfering party to have a financial interest in the business of the third party which is in the nature of an investment in order to justify the interference.2 Therefore, the jury instruction as given was incorrect since the financial interest used in the jury instruction was not limited to one in the nature of an investment. Furthermore, a privilege to interfere with a third party’s conduct does not include the purposeful causing of a breach of contract.3 The instruction also did not cover that limitation.
Because of our disposition of the jury instruction question, it is not necessary to discuss appellant’s other points on appeal. We REVERSE the judgment and REMAND the case for a new trial.
BOARDMAN, Acting C.J., and OTT, J., concur. . W. Prosser, Law of Tort, § 129 (4th Ed. 1971).
. Restatement 2d, Torts, § 767 (1979).
.Restatement 2d, Torts, § 777 (1979).
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By
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McCURDY v. J.C. Collis & Exxon Corp., 508 So. 2d 380 (Fla. 1st DCA 1987)…d at 144-145; Babson Bros. Co. v. Allison, 337 So. 2d 848, 850 (Fla. 1st DCA 1976), cert. denied, 348 So. 2d 944 (Fla.1977). In other words, the privilege does not encompass the purposeful causing of a breach of contract. Yoder v. Shell Oil Company, 405 So. 2d 743, 744 (Fla. 2d DCA 1981); Restatement (2d) of Torts, s. 777 (1977). The justification for intentional interference “depends upon a balancing of the importance, social and private, of the objective advanced by the interference against the importance o…
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Monco Enters., Inc. v. Ziebart Corp., 673 So. 2d 491 (Fla. 1st DCA 1996)…haser of the dealership. The Fifth Circuit stated that when a plaintiff proves a prima facie case of interference, the defendant has the burden of avoiding liability by showing that his conduct is privileged or justified. See Yoder v. Shell Oil Co., 405 So. 2d 743, 744 (Fla. 2d DCA 1981), review denied, 412 So. 2d 470 (Fla.1982) (citing Frank Coulson and stating that the privilege to interfere in a contract because of a financial interest is not unlimited). Accordingly, it is clear in the instant case that ap…
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Morsani v. Major League Baseball, 663 So. 2d 653 (Fla. 2d DCA 1995)…e third party which is in the nature of an investment in order to justify the interfer-ence_ Furthermore, a privilege to interfere with a third party’s conduct does not include the purposeful causing of a breach of contract. Yoder v. Shell Oil Co., 405 So. 2d 743, 744 (Fla. 2d DCA 1981), review denied, 412 So. 2d 470 (Fla.1982). Where there is a qualified privilege to interfere with a business relationship, the privilege carries with it the obligation to employ means that are not improper. McCurdy v. Collis…
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Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Coulson v. Gen. Motors Corp., 488 F.2d 202 (5th Cir. 1974)