## Facts

- Jerry Janvrin operated J&J Trucking, a hauling business in the Bakken region that hired drivers to transport equipment for oil-field suppliers.
- CTAP, LLC operated a terminal in Bowman, North Dakota; J&J derived about 96% of its income from CTAP-related work.
- Continental Resources was a major oil producer in the region and accounted for about 60% of CTAP’s Bowman terminal business from 2010 to 2014.
- After a Continental driver hit and killed two cows owned by Janvrin’s family during a blizzard, Janvrin gave a local newspaper interview criticizing unsafe driving on rural roads without naming Continental.
- Following internal complaints about the article, a Continental director contacted CTAP; evidence supported that Continental requested J&J be banned from hauling for Continental.
- CTAP removed J&J from its Bowman terminal operations, effectively cutting off J&J’s main source of revenue and causing severe business losses.

## Issues

1. Whether sufficient evidence supported a finding that Continental intentionally interfered with Janvrin’s business relationship with CTAP (by desiring interference or knowing it was substantially certain to occur).
2. Whether Continental’s conduct could be found improper and the legal cause of CTAP’s termination of J&J’s work.
3. Whether the district court abused its discretion in instructing the jury on “improper interference,” including the distinction between refusing to deal and inducing a third party to sever an existing relationship.
4. Whether substantial evidence supported the compensatory and punitive damages awards.

## Decision

- The Eighth Circuit affirmed the judgment for Janvrin on all grounds.
- The evidence permitted a reasonable jury to find Continental intended interference, given its economic leverage over CTAP and the request to exclude J&J.
- The evidence permitted findings of improper interference and legal causation, not merely a lawful refusal to deal.
- The “improper interference” instruction correctly stated governing law and was not an abuse of discretion.
- Substantial evidence supported both compensatory damages (lost business tied to CTAP) and punitive damages (retaliatory, willful or reckless conduct inferred from the circumstances).

## Legal Principles

- Tortious interference with a business relationship requires: (1) a protected relationship with a third party, (2) intentional and unjustified interference, (3) legal causation, and (4) damages.
- Intent is satisfied if the actor desires interference or knows interference is substantially certain to result from its conduct.
- “Improper” interference may be assessed using factor-based considerations, including the nature of the conduct and the actor’s motive.
- A business may refuse to deal with another, but may incur liability by using its economic power to induce a third party to terminate an existing relationship under improper circumstances.
- Punitive damages may be upheld where the evidence supports a finding of willful, wanton, or reckless disregard of another’s rights.

## Conclusion

The Eighth Circuit upheld a jury verdict finding Continental liable for tortious interference after it used its leverage as a key customer to induce CTAP to remove Janvrin’s trucking company following his public safety comments, and it affirmed both compensatory and punitive damages as supported by substantial evidence.


Janvrin v. Cont’l Res., Inc., 934 F.3d 845 (8th Cir. 2019)