## Facts

- William M. Joel (professionally known as Billy Joel) entered a management agreement under which Frank Management, Inc. (FMI), through its president Francis X. Weber, managed Joel’s business and personal affairs.
- Joel later sued Weber and FMI in a separate action seeking a declaration that he validly terminated the agreement, alleging fraud and breach of fiduciary duty by FMI through Weber.
- FMI brought a separate action against Christie B. Joel (Christie Brinkley Joel), Joel’s wife at the time, alleging she tortiously interfered with the management agreement and seeking $11 million in damages.
- FMI alleged that between 1986 and 1989 Brinkley “wrongfully” and “maliciously” induced Joel to violate and repudiate the agreement, but pleaded no specific acts supporting that assertion.
- The only stated basis for Brinkley’s alleged motive was that she harbored “ill feelings and malice” toward FMI because Weber participated in negotiating a 1985 antenuptial agreement between Brinkley and Joel.
- The management agreement had been renewed in 1987 and 1989, after Brinkley and Joel were married.
- The actions were consolidated, and Brinkley moved to dismiss FMI’s complaint under CPLR 3211(a)(7) for failure to state a cause of action.

## Issues

1. Whether New York law provides a spouse absolute immunity from liability for tortious interference with a contract between the other spouse and a third party.
2. Whether FMI’s complaint alleged nonconclusory facts sufficient to state a claim for tortious interference with contract under CPLR 3211(a)(7).

## Decision

- The court rejected the claim that a spouse has absolute immunity from tortious-interference liability based solely on marital status.
- The court granted Brinkley’s CPLR 3211(a)(7) motion and dismissed FMI’s complaint for failure to state a cause of action.
- The court held that FMI’s allegations were conclusory and did not plead specific facts showing Brinkley intentionally procured a breach by wrongful means or without justification.

## Legal Principles

- Marital status alone does not create an absolute bar to a tortious-interference claim involving one spouse’s contract with a third party.
- To plead tortious interference with contract, a complaint must allege facts supporting: a valid contract, defendant’s knowledge, intentional procurement of a breach, and resulting damages; conclusory recitations of these elements are insufficient.
- Allegations of motive (e.g., “ill feelings” or “malice”) do not substitute for factual allegations of actionable conduct that induced a breach.
- On a CPLR 3211(a)(7) motion, the court accepts factual allegations as true but need not accept bare legal conclusions unsupported by pleaded facts.

## Conclusion

The court declined to recognize absolute spousal immunity for tortious interference with contract, but dismissed FMI’s claim because it pleaded only generalized assertions of malice and inducement, not specific facts showing that Brinkley wrongfully caused Joel to breach the management agreement.


Joel v. Weber, 153 Misc. 2d 549, 581 N.Y.S.2d 579 (Sup. Ct. N.Y. Cnty. 1992)