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Keywords

contracttortequitable relief
contractplaintiffdefendantequitygood faithequitable relief

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American Broadcasting Companies, Inc. v. Wolf, 52 N.Y.2d 394, 420 N.E.2d 363, 438 N.Y.S.2d 482

Facts

Warner Wolf, a sportscaster employed by ABC since 1976, entered into an employment agreement with ABC that included a good-faith negotiation clause for contract renewal. As the contract neared expiration, Wolf engaged in negotiations with CBS without informing ABC, ultimately signing a contract with CBS after the exclusive negotiation period with ABC had ended. ABC sought injunctive relief to prevent Wolf from working with CBS, claiming he breached the good-faith negotiation clause of his contract.

Warner Wolf, a sportscaster who has developed a rather colorful and unique on-the-air personality, had been employed by ABC since 1976.

Issue

Whether ABC is entitled to equitable relief against Warner Wolf for breaching a good-faith negotiation provision of an expired broadcasting contract.

The issue is whether plaintiff American Broadcasting Companies, Incorporated (ABC), is entitled to equitable relief against defendant Warner Wolf, a New York City sportscaster, because of Wolf's breach of a good faith negotiation provision of a now expired broadcasting contract with ABC.

Rule

Equitable relief against a former employee is generally not available after the termination of an employment contract unless there is an express anticompetitive covenant or evidence of tortious conduct.

Courts of equity historically have refused to order an individual to perform a contract for personal services.

Analysis

The court found that while Wolf breached the good-faith negotiation clause, the absence of an existing employment agreement and the lack of an express anticompetitive covenant meant that ABC could not obtain injunctive relief. The court emphasized that granting such relief would unduly interfere with Wolf's ability to earn a living and inhibit free competition, as the only injury to ABC was the loss of a competitive edge.

Applying these principles, it is apparent that ABC's request for injunctive relief must fail. There is no existing employment agreement between the parties; the original contract terminated in March, 1980.

Conclusion

The court affirmed the Appellate Division's decision, concluding that ABC was not entitled to the injunctive relief it sought against Wolf.

Accordingly, the order of the Appellate Division should be affirmed.

Who won?

Warner Wolf prevailed in the case because the court determined that ABC was not entitled to equitable relief due to the absence of an existing contract and the nature of the breach.

Fuchsberg, J., dissented with opinion.

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