Can tortious interference claims succeed based on improper purpose alone? Eldridge v. Johndrow Explained

The Utah Supreme Court’s decision in Eldridge v. Johndrow fundamentally reshaped tortious interference law by eliminating the improper purpose prong that had existed since the court’s 1982 decision in Leigh Furniture & Carpet Co. v. Isom.

Background and Facts

Joseph and Lindsey Eldridge operated property management companies serving wealthy homeowners in Summit County. After a friendship with David Johndrow soured over mutual accusations, Johndrow hired an investigative team that uncovered embarrassing but truthful information about the Eldridges, including liens, foreclosure, and an old felony conviction. When the Eldridges refused his demands for retraction and compensation, Johndrow disseminated this information to at least nine of their institutional clients. The Eldridges sued for tortious interference based on both improper means and improper purpose theories.

Key Legal Issues

The central issue was whether tortious interference liability could be based solely on improper purpose when the defendant’s means were proper. The district court granted summary judgment on the improper means claim, finding the disseminated information was substantially true, but denied summary judgment on the improper purpose claim, following existing precedent from Pratt v. Prodata.

Court’s Analysis and Holding

The court conducted extensive stare decisis analysis and concluded that the improper purpose doctrine should be abandoned. The court found that the doctrine provided inadequate guidance to courts and juries, created unpredictable outcomes based on “jurors’ personal sympathies,” and failed to give parties adequate notice of their rights and duties. The court noted that in thirty-two years since Leigh Furniture, only three cases had successfully applied improper purpose liability, demonstrating the doctrine’s minimal practical impact.

Practice Implications

This decision requires a complete restructuring of tortious interference claims in Utah. Plaintiffs can no longer rely on proving malicious intent alone but must demonstrate that defendants employed improper means. The court clarified that defendants’ motivations remain relevant for proving intent (since tortious interference remains an intentional tort) and may be relevant to determining whether particular means were improper, but malice alone cannot establish liability.