## Facts

- Leigh Furniture and Carpet Company sold Isom a going-concern furniture store under a contract for $80,000, with $20,000 down and the remainder payable monthly with interest over ten years.
- The transaction included a ten-year lease of the premises and an option for Isom to purchase the building after paying the contract balance.
- Isom presented evidence that, after the sale, Leigh and agents repeatedly visited the store during business hours to criticize operations and complained that the lease and option hindered Leigh’s desire to sell the building.
- Isom offered evidence that Leigh engaged in a course of conduct that disrupted the business, including filing allegedly baseless lawsuits, discouraging Isom from obtaining experienced help, and threatening to cancel the contract and resell the business.
- In 1975, with about $27,000 remaining, Leigh sued to repossess the business, terminate Isom’s contractual interest, and obtain any deficiency after liquidation.
- Before learning of the complaint, Isom tendered the full remaining balance and attempted to exercise the purchase option; Leigh refused the tender and indicated he would not permit the sale.
- After service of the repossession complaint, Isom closed the business and filed bankruptcy, then counterclaimed for intentional, malicious conduct that forced him into bankruptcy.

## Issues

1. Whether Utah recognizes a cause of action for intentional interference with prospective economic relations.
2. Whether the evidence supported the jury’s finding that Leigh intentionally interfered with Isom’s prospective economic relations through improper purpose or improper means and caused compensable harm.
3. Whether the trial court properly reduced the jury’s punitive damages award by remittitur.

## Decision

- The Utah Supreme Court held that Utah recognizes the tort of intentional interference with prospective economic relations.
- The court affirmed the jury’s verdict for Isom on liability and compensatory damages, finding substantial evidence of actionable interference and causation.
- The court held the remittitur of punitive damages was improper and reinstated the jury’s original punitive award.
- Disposition: judgment for Isom on the counterclaim affirmed as modified to restore the full punitive damages amount.

## Legal Principles

- Intentional interference with prospective economic relations is actionable when a defendant intentionally causes injury to another’s economic interests by acting with an improper purpose or using improper means.
- Improper purpose focuses on whether the defendant’s predominant motive is to injure or destroy the plaintiff’s economic interests rather than to pursue legitimate interests.
- Improper means includes independently wrongful conduct (such as harassment, threats, or unjustified litigation) used to interfere with another’s business expectancies.
- Punitive damages should not be reduced by mechanical ratios; review turns on the character of the conduct, the harm caused, and the objectives of punishment and deterrence.

## Conclusion

Utah recognized intentional interference with prospective economic relations and upheld a verdict where a seller’s alleged harassment, threats, and groundless litigation supported findings of improper purpose or improper means causing business failure; the court also restored the jury’s punitive damages after rejecting a ratio-based remittitur.


Leigh Furniture & Carpet Co. v. Isom, 657 P.2d 293 (Utah 1982)