Joseph Eldridge, Lindsey Eldridge, Harrison Companies, LLC, and Harrison Companies Property Management, LLC, Dba…

Summary

The Utah Supreme Court held that tortious interference with economic relations cannot be established solely by proof of an improper purpose; the plaintiff must prove interference by improper means. The court rejected the prior improper-purpose doctrine because it was weakly grounded, poorly defined, difficult to review, and likely to chill legitimate commercial conduct and speech. Applying the new rule, the court held that the Eldridges lacked evidence of improper means and reversed the denial of summary judgment.