What is intentional interference with contractual relations?

The elements of a cause of action for intentional interference with contractual relations are:

  1. the existence of a valid contract between the plaintiff and a third party;
  2. the defendant’s knowledge of that contract;
  3. the defendant’s intentional acts designed to induce a breach or disruption of the contractual relationship;
  4. actual breach or disruption of the contractual relationship; and
  5. resulting damage.

Redfearn v. Trader Joe’s Co. (2018) 20 Cal.App.5th 989, 997 (citation omitted).

Only “a stranger to a contract” may be liable for interfering with it. Mintz v. Blue Cross of California (2009) 172 Cal.App.4th 1594, 1603.

“[A] cause of action for intentional interference with contract requires an underlying enforceable contract. Where there is no existing, enforceable contract, only a claim for interference with prospective advantage may be pleaded.” PMC, Inc. v. Saban Entertainment, Inc. (1996) 45 Cal.App.4th 579, 601.

“The question is whether a plaintiff must plead and prove that the defendant engaged in wrongful acts with the specific intent of interfering with the plaintiff’s business expectancy. We conclude that specific intent is not a required element of the tort of interference with prospective economic advantage. While a plaintiff may satisfy the intent requirement by pleading specific intent, i.e., that the defendant desired to interfere with the plaintiff’s prospective economic advantage, a plaintiff may alternately plead that the defendant knew that the interference was certain or substantially certain to occur as a result of its action.” Korea Supply Co. v. Lockheed Martin Corp. (2003) 29 Cal.4th 1134, 1154.

A contracting party cannot be held to interfere with its own contract. Asahi Kasei Pharma Co. v. Actelion Ltd. (2013) 222 Cal.App.4th 945, 961.

CACI 2201 sets forth the elements of the tort of interference with contract. CACI 2201; see PG&E v. Bear Stearns (1990) 50 Cal.3d 1118, 1126.

Useful Rulings on Intentional Interference with Contractual Relations

Recent Rulings on Intentional Interference with Contractual Relations

CITRUS OBSTETRICS & GYNECOLGY VS CITRUS VALLEY HEALTH

First Cause of Action: Intentional Interference with Contractual Relations (i.e., Issues Nos. 1-13) “The elements which a plaintiff must plead to state the cause of action for intentional interference with contractual relations are (1) a valid contract between plaintiff and a third party; (2) defendant's knowledge of this contract; (3) defendant's intentional acts designed to induce a breach or disruption of the contractual relationship; (4) actual breach or disruption of the contractual relationship; and (

  • Hearing

    Aug 06, 2020

  • Type

    Business

  • Sub Type

    Intellectual Property

KOUROSH IZADPANAHI VS MARIA ALMA YOLANDA IBARRA DABDOUB, ET AL.

These facts do not set forth intentional interference with contractual relations, particularly because the party with whom Plaintiff had contract had passed away before receipt of this email communication, such that the Court cannot determine how any breach or disruption of a contractual relationship would have occurred as a result of this email communication. Thus, Plaintiff has failed to sufficiently state a claim for intentional interference with contractual relations.

  • Hearing

    Jul 26, 2020

(NO CASE NAME AVAILABLE)

Plaintiff advises that it does not intend to present evidence of Commodity Trucking’s “financial status” or its “corporate size” unless and until trial reaches a punitive damages phase (Opposition, 4:14-15), but contends that evidence regarding Commodity Trucking’s profits is essential to its causes of action for intentional interference with contractual relations and Business & Professions Code § 17200. (Id., 3:10-13.)

  • Hearing

    Jul 20, 2020

KATIE O CONNELL MARSH VS GAUMONT TELEVISION USA LLC

A cause of action for interference with contractual relations is governed by a two-year statute of limitations. (Knoell v. Petrovich (1999) 76 Cal.App.4th 164, 168.) The statute of limitations for a cause of action for inducing breach of a contract is two years. (Kenworthy v. Brown (1967) 248 Cal.App.2d 298, 301.) The statute of limitations for a cause of action begins on the date which the wrongful act occurred. (Trembath v. Digardi (1974) 43 Cal.App.3d 834, 838.)

  • Hearing

    Jul 10, 2020

XIAOFAN SUN VS HRC FERTILITY CLINIC, ET AL.

Plaintiff filed a Complaint on May 15, 2019, alleging six causes of action sounding in: (1) Fraud; (2) Fraudulent Concealment; (3) Intentional Interference with Contractual Relations; (4) Professional Negligence; (5) Negligent Training and Supervision; and (6) Intentional Infliction of Emotional Distress.

  • Hearing

    Jul 10, 2020

  • Type

    Personal Injury/ Tort

  • Sub Type

    other

SUPER NATURAL, INC. VS PENROSE, LLC

Procedural History On March 5, 2020, Plaintiff filed a complaint against Defendant for declaratory relief, breach of contract, implied covenant of good faith and fair dealing, intentional interference with contractual relations, intentional interference with prospective economic advantage, and injunctive relief. On March 17, 2020, Defendant filed an answer. On May 22, 2020, the court granted Plaintiff’s ex parte application for a TRO and OSC re: preliminary injunction.

  • Hearing

    Jul 09, 2020

  • Type

    Real Property

  • Sub Type

    other

ALEXANDRIA EQUITIES NO.7 LLC VS PRECISION AGRITECH INC.,

First Cause of Action – Intentional Interference with Contract To state a claim for intentional interference with contractual relations, a plaintiff (or cross-complainant) must allege (1) a valid contract between plaintiff and a third party; (2) defendant's knowledge of this contract; (3) defendant's intentional acts designed to induce a breach or disruption of the contractual relationship; (4) actual breach or disruption of the contractual relationship caused by the defendant; and (5) resulting damage.

  • Hearing

    Jul 08, 2020

  • Type

    Personal Injury/ Tort

  • Sub Type

    Fraud

  • Judge

    Lori Ann Fournier or Olivia Rosales

  • County

    Los Angeles County, CA

JAMES GIBB VS MARADA ENTERPRISES LLC ET AL

The Complaint asserts causes of action for breach of contract and intentional interference with contractual relations. Marada filed a Cross-Complaint against Gibb on October 9, 2019. The operative Amended Cross-Complaint (“AXC”) was filed on February 24, 2020, and asserts causes of action for (1) breach of contract, (2) breach of fiduciary duty, (3) fraud, (4), conversion, (5) unjust enrichment, and (6) accounting.

  • Hearing

    Jul 07, 2020

TAMAR SECURITIES, LLC VS TOBIE ALEXANDER RODRIGUEZ

However, this argument is without merit, as Plaintiff has identified that such information is relevant to proving its claims of intentional interference with contractual relations and defamation against Defendant given that such information is necessary to determine whether Defendant improperly solicited Plaintiff’s clients.

  • Hearing

    Jul 02, 2020

  • Type

    Personal Injury/ Tort

  • Sub Type

    other

(NO CASE NAME AVAILABLE)

The FACC asserts causes of action for breach of oral contract, unfair business practice, negligent misrepresentation, intentional misrepresentation, false promise, intentional interference of contractual relations, intentional interference with an economic advantage, negligent interference with an economic advantage, and defamation per se.

  • Hearing

    Jul 02, 2020

SMITH VS. PERKINS

Count 13: Intentional Interference. Count 13 is labeled “intentional interference.” This cause of action is ambiguous as to whether plaintiffs are attempting to pursue a cause of action for intentional interference with the construction contract, or intentional interference with prospective economic relations; these are two distinct torts.

  • Hearing

    Jul 01, 2020

FAYE PIERSON, ET AL. VS. JESUS DURAZO, ET AL.

The Complaint was filed on January 02, 2018, alleging eight (8) causes of action for (1) Breach of Contract, (2) Elder Abuse, (3) Intentional Interference with Expected Inheritance, (4) Intentional Interference with Prospective Economic Advantage, (5) Intentional Interference with Contractual Relations, (6) Breach of Contract, and (7) Negligent Interference with Prospective Economic Advantage. PRESENTATION: Motion to Compel The motion to compel was filed on March 13, 2020.

  • Hearing

    Jun 30, 2020

  • Type

    Personal Injury/ Tort

  • Sub Type

    other

BLF INC. DBA LARRABURE FRAMING, A CALIFORNIA CORPORATION,, ET AL. VS CARPENTERS-CONTRACTORS COOPERATION COMMITTEE INC., A CALIFORNIA CORPORATION,, ET AL.

On September 27, 2019, Plaintiffs filed a complaint against Defendants alleging: 1) Intentional Interference with Contractual Relations; 2) Interference with Prospective Economic Advantage; 3) Negligent Interference with Prospective Economic Relations; and 4) Injunctive Relief On January 27, 2020, this court dismissed Plaintiff’s Complaint upon granting Defendants’ Anti-SLAPP Motion to Strike (CCP §425.16). Defendants now move this court for attorney fees under CCP §425.16(c)(1) and CRC Rule 3.1702.

  • Hearing

    Jun 30, 2020

  • Type

    Business

  • Sub Type

    Intellectual Property

  • Judge

    Paul A. Bacigalupo or Virginia Keeny

  • County

    Los Angeles County, CA

PARADIGM TREATMENT CENTERS, LLC, A LIMITED LIABILITY COMPANY, VS PACIFIC TEEN TREATMENT, LLC, A LIMITED LIABILITY COMPANY, ET AL.

.; (6) intentional interference with contractual relations; (7) intentional interference with prospective economic relations; (8) negligent interference with contractual relations; (9) fraud (10) violation of California Penal Code § 502; (11) conversion; (12) breach of implied covenant of good faith and fair dealing; and (13) defamation. Defendants Pacific Teen Treatment, LLC and Jeremy Manne filed a demurrer to the ninth and twelfth causes of action.

  • Hearing

    Jun 30, 2020

BARRY REGENSTEIN VS ROBERT S. ELLIN, ET AL.

Fourth Cause of Action (Intentional Interference with Contractual Relations). This cause of action is asserted against Defendant Ellin only. [I]n California, the law is settled that “a stranger to a contract may be liable in tort for intentionally interfering with the performance of the contract.” (Citation omitted.)

  • Hearing

    Jun 30, 2020

  • Type

    Personal Injury/ Tort

  • Sub Type

    Fraud

CJWORLD-LA, ET AL. VS 147-151 W. 25TH ST. LLC, ET AL.

Eighth Cause of Action: Intentional Interference with Contract “The elements of the cause of action of intentional interference with contractual relations are ‘1) a valid contract between plaintiff and a third party; (2) defendant’s knowledge of this contract; (3) defendant’s intentional acts designed to induce a breach or disruption of the contractual relationship; (4) actual breach or disruption of the contractual relationship; and (5) resulting damage.' [Citations.]

  • Hearing

    Jun 29, 2020

  • Type

    Real Property

  • Sub Type

    other

  • Judge Elaine Lu
  • County

    Los Angeles County, CA

START INC VS LONMAR GLOBAL RISKS LIMITED ET AL

The operative pleading, Start’s second amended complaint (“SAC”), alleges causes of action for (1) breach of the implied covenant of good faith and fair dealing (RSA), (2) breach of contract (RSA), (3) fraud in the performance (RSA, Lonmar), (4) intentional interference with economic advantage and prospective economic advantage (Buhrman), (5) intentional interference with contractual relations (Buhrman), (6) professional negligence (Brown & Brown, All Risks), (7) negligent misrepresentation (RSA, Lonmar, Brown

  • Hearing

    Jun 26, 2020

  • Judge Donna Geck
  • County

    Santa Barbara County, CA

ANDREA LOMBARDI VS RONALD F LOMBARDI AND KATHLEEN A LOMBARDI

In Nos. 18-22, Defendants move to strike the allegations seeking an award for punitive damages from the Prayer of the SAC: Prayer ¶20 [5th (breach of fiduciary duty) COA against Eugene and Lombardi Sons], ¶27 [7th (intentional interference with prospective economic relations (“IIPER”)) COA against Eugene], ¶35 [10th (intentional interference with contractual relations (“IICR”)) COA against Eugene], ¶41 [11th (fraudulent transfer) COA against Eugene and Lombardi Sons], and ¶47 [12th (fraudulent transfer) COA

  • Hearing

    Jun 26, 2020

  • Type

    Real Property

  • Sub Type

    other

CROWDFOOD, INC. VS ALEX CANTER, ET AL.

To state a claim for a cause of action for intentional interference with contractual relations, a plaintiff must plead “(1) the existence of a valid contract between the plaintiff and a third party; (2) the defendant's knowledge of that contract; (3) the defendant's intentional acts designed to induce a breach or disruption of the contractual relationship; (4) actual breach or disruption of the contractual relationship; and (5) resulting damage. [citation.]” (Reeves v.

  • Hearing

    Jun 26, 2020

  • Type

    Contract

  • Sub Type

    Breach

BACK OFFICE, LLC VS RIVERSIDE PROPERTIES, LTD., ET AL.

Matsushita Electric Corp. of America (2004) 115 Cal.App.4th 168 to support their contention that their tort claim for intentional interference with contractual relations does not sound in tort. In JRS Products, Inc., the court held a party to a contract cannot recover damages in tort based on a breach of contract.

  • Hearing

    Jun 26, 2020

  • Type

    Real Property

  • Sub Type

    Landlord Tenant

  • Judge

    Paul A. Bacigalupo or Virginia Keeny

  • County

    Los Angeles County, CA

K SWISS INTERNATIONAL LTD VS CARTER INTERNATIONAL S A

Cross-Complainant filed the operative Second Amended Cross-Complaint (“SAXC”) against Cross-Defendants alleging causes of action for: (1) breach of written contracts; (2) breach of the implied covenant of good faith and fair dealing; (3) breach of implied warranty of merchantability; (4) breach of implied warranty of fitness; (5) fraud; (6) unfair competition; (7) intentional interference with contractual relations; and (8) negligent interference with prospective business advantage.

  • Hearing

    Jun 25, 2020

KEITH OLDHAM, ET AL VS JAY PRESS, ET AL

As such, plaintiffs have failed to raise a triable issue of material fact. 6th cause of action for intentional interference with contract “The elements which a plaintiff must plead to state the cause of action for intentional interference with contractual relations are (1) a valid contract between plaintiff and a third party; (2) defendant’s knowledge of this contract; (3) defendant’s intentional acts designed to induce a breach or disruption of the contractual relationship; (4) actual breach or disruption

  • Hearing

    Jun 25, 2020

  • Type

    Real Property

  • Sub Type

    Quiet Title

  • County

    Los Angeles County, CA

SUNSET HILLS CAR WASH INC VS GENERAL BARRICADE LLC

General filed an Answer and Cross-Complaint with Community Redevelopment Association LLC, dba Liberty Media Group (“Liberty”) on November 30, 2018, alleging 15 causes of action: Breach of Contract Fraud Wrongful Eviction Negligent Misrepresentation Breach of Implied Covenant of Good Faith and Fair Dealing Breach of Implied Covenant of Quiet Enjoyment Intentional Interference with Contract Trespass to Real Property Conversion Trespass to Chattels Intentional Interference with Contractual Relations

  • Hearing

    Jun 22, 2020

  • Type

    Personal Injury/ Tort

  • Sub Type

    Fraud

DUAL DIAGNOSIS TREATMENT CENTER VS. HEALTH NET, INC., ET AL

.; (5) intentional interference with contractual relations; and (6) declaratory relief. Health Net asserts that Plaintiffs/Cross-Defendants engaged in insurance fraud by exploiting the Affordable Care Act and obtaining millions of dollars in reimbursement from Health Net for substance abuse treatment services. Health Net alleges that cross defendants purchased substance abuse treatment patients from “body brokers.” Health Net successfully sought leave to file a First Amended Cross Complaint (FAXC).

  • Hearing

    Jun 22, 2020

  • Judge

    Paul A. Bacigalupo or Virginia Keeny

  • County

    Los Angeles County, CA

(NO CASE NAME AVAILABLE)

In this case, the Complaint alleges five causes of action: intentional interference with contractual relations, intentional interference with prospective economic relations, defamation per se, false light, and unfair business practices. (Compl. at p. 1.)

  • Hearing

    Jun 22, 2020

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