## Facts

- Joseph and Lindsey Eldridge operated luxury residential property-management businesses that depended on client trust.
- David Johndrow had referred clients to the Eldridges, later had a personal dispute with them, and learned embarrassing but accurate facts about them (including liens, a foreclosure, an old felony conviction, and negative media reports).
- Johndrow threatened to disclose this information to the Eldridges’ clients unless they retracted statements about him and returned a cell phone he claimed was stolen.
- After the Eldridges refused, Johndrow sent the truthful information to several clients, allegedly damaging the Eldridges’ business relationships.
- The Eldridges sued for intentional interference with economic relations (IIER), alleging interference by (a) improper means and (b) improper purpose.

## Issues

1. Whether Utah recognizes IIER liability based solely on a defendant’s improper purpose when the defendant’s means are otherwise lawful, including communicating truthful information.
2. Whether IIER in Utah requires proof of improper means as an element of the tort.

## Decision

- The Utah Supreme Court reversed the district court’s denial of summary judgment on the Eldridges’ improper-purpose IIER theory and remanded.
- The court held that improper purpose, standing alone, is not an independent basis for IIER liability in Utah.
- The court required plaintiffs to prove improper means; lawful conduct motivated by spite is insufficient.
- Because the trial court found no evidence of improper means and the remaining claim rested only on alleged improper motive, Johndrow was entitled to summary judgment on that theory.

## Legal Principles

- IIER in Utah requires proof that the defendant interfered through improper means; improper purpose alone cannot establish liability.
- Improper means focuses on objective wrongdoing (unlawful acts or independently actionable conduct), not subjective motive.
- Communicating truthful information is generally not tortious interference, consistent with Restatement (Second) of Torts § 772(a).
- Prior Utah doctrine allowing liability based on improper purpose even when means were proper was rejected.

## Conclusion

The Utah Supreme Court narrowed IIER by requiring improper means in all cases, eliminating liability based solely on improper motive where the defendant’s conduct is lawful, including the disclosure of truthful information.


Eldridge v. Johndrow, 345 P.3d 553 (Utah 2015)