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Keywords

torttrialmotion
tortplaintiffdefendant

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Tuttle v. Buck, 107 Minn. 145, 119 N.W. 946, 22 L.R.A.N.S. 599, 131 Am.St.Rep. 446, 16 Am.Ann.Cas. 807

Facts

Edward C. Tuttle, a barber in Howard Lake, Minnesota, had operated a successful barber shop for over ten years. However, Cassius M. Buck, a wealthy banker, maliciously opened a competing barber shop with the intent to ruin Tuttle's business. Buck employed barbers to attract Tuttle's customers and used his influence to spread false reports about Tuttle, ultimately leading to a significant decline in Tuttle's business and income.

That the defendant, during the period of about 12 months last past, has wrongfully, unlawfully, and maliciously endeavored to destroy plaintiff's said business and compel plaintiff to abandon the same.

Issue

Did the complaint state a valid cause of action for malicious interference with business?

Did the complaint state a valid cause of action for malicious interference with business?

Rule

The law does not take into account motives as constituting an element of civil wrong unless the act itself is unlawful. However, if a person starts a business not for profit but solely to drive a competitor out of business, this may constitute an actionable tort.

It has been said that the law deals only with externals, and that a lawful act cannot be made the foundation of an action because it was done with an evil motive.

Analysis

The court analyzed whether Buck's actions constituted lawful competition or malicious interference. While competition is generally permissible, the court noted that if a business is established solely to harm a competitor without any legitimate purpose, it may be deemed a wrongful act. The majority of justices concluded that Tuttle's complaint sufficiently alleged that Buck's actions were not merely competitive but maliciously intended to destroy Tuttle's business.

To divert to one's self the customers of a business rival by the offer of goods at lower prices is in general a legitimate mode of serving one's own interest, and justifiable as fair competition. But when a man starts an opposition place of business, not for the sake of profit to himself, but regardless of loss to himself, and for the sole purpose of driving his competitor out of business, and with the intention of himself retiring upon the accomplishment of his malevolent purpose, he is guilty of a wanton wrong and an actionable tort.

Conclusion

The court affirmed the order denying Buck's motion for a new trial, concluding that Tuttle's complaint adequately stated a cause of action for malicious interference.

A majority of the Justices, however, are of the opinion that, on the principle declared in the foregoing opinion, the complaint states a cause of action, and the order is therefore affirmed.

Who won?

Edward C. Tuttle prevailed in the case because the court found that his complaint sufficiently alleged malicious intent behind Buck's actions, which constituted an actionable tort.

The majority of justices concluded that Tuttle's complaint sufficiently alleged that Buck's actions were not merely competitive but maliciously intended to destroy Tuttle's business.

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