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Keywords

contractbreach of contracttortplaintiffdefendantattorneyliabilitystatutecompliancepiracy

contractbreach of contractplaintiffdefendant

Related Cases

Royal Realty Co. v. Levin, 244 Minn. 288, 69 N.W.2d 667

Facts

The plaintiff, a real estate company, negotiated an agreement with Anna and Ann Lynam to purchase their home in St. Paul. After reaching an oral agreement, the plaintiff's agent was informed by one of the Lynams' attorneys that the written contract would be executed the following morning. However, when the agent arrived the next day, he discovered that the property had already been sold to another party. The plaintiff alleged that the attorney's representation was false and part of a conspiracy to defraud them.

On September 3, 1952, it negotiated an agreement with Anna and Ann Lynam for the purchase of their home in St. Paul.

Issue

Did the complaint set forth a legally sufficient claim for relief for inducing breach of contract?

Rule

An action for inducing breach of contract may be maintained even if the means employed are lawful, and noncompliance with the statute of frauds does not relieve the interfering party of liability.

If the interference is without sufficient justification, an action for inducing breach of contract may be maintained even though the means employed in inducing the breach are in themselves lawful.

Analysis

The court analyzed whether the complaint sufficiently alleged the elements necessary for a claim of inducing breach of contract. It concluded that the allegations implied that the defendants induced the Lynams to breach the contract and that the breach was without justification. The court noted that the complaint did not need to state the circumstances of the alleged fraud with particularity, as it was a separate tort.

The complaint clearly alleges the defendants had knowledge of the existence of the contract but does not specifically allege that the defendants persuaded or otherwise procured the Lynams to withdraw from the contract.

Conclusion

The court reversed the District Court's dismissal, holding that the complaint sufficiently alleged a claim for inducing breach of contract, while the fraud claim was not supported.

Reversed.

Who won?

The plaintiff, Royal Realty Co., prevailed because the Supreme Court found that the allegations in the complaint were sufficient to state a claim for inducing breach of contract.

The plaintiff, a real estate company, made the following allegations in its complaint.

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Connick v. Thompson, 563 U.S. 51, 131 S.Ct. 1350, 179 L.Ed.2d 417, 79 USLW 4195, 11 Cal. Daily Op. Serv. 3740, 2011 Daily Journal D.A.R. 4526, 22 Fla. L. Weekly Fed. S 887