## Facts

- Revere manufactured resistive strain gauge force transducers, including a proprietary tractor draft sensor used to regulate plowing depth.
- Deere contracted with Revere to develop and supply draft sensors, exchanging technical information subject to confidentiality restrictions; Revere’s drawings bore nondisclosure legends.
- Two Revere employees, Greg Eckart and Francis Delfino, worked closely with Deere and had signed employment/nondisclosure agreements barring disclosure of nonpublic technical information and appropriation of inventions or discoveries arising from Revere work.
- After Revere was acquired, Eckart and Delfino formed a new company and developed a welded draft sensor that Revere contended was substantially similar to Revere’s sensor.
- In March 1989, Eckart and Delfino presented Deere with drawings and a cost proposal; Deere agreed to buy the welded sensor from their company.
- Eckart and Delfino resigned from Revere, and Deere shifted purchasing from Revere to the new company.
- Revere sued Deere for tortious interference with the employees’ contracts, misappropriation of trade secrets, and civil conspiracy.
- A jury found for Revere on tortious interference and civil conspiracy, for Deere on trade-secret misappropriation, and awarded compensatory and punitive damages.

## Issues

1. Whether Revere’s employment/nondisclosure agreements were enforceable and sufficiently definite to support a tortious-interference claim.
2. Whether substantial evidence supported findings that Deere knowingly, intentionally, and improperly induced breaches of those agreements, causing damage to Revere.
3. Whether Revere could recover separate compensatory damages for both tortious interference and civil conspiracy based on the same injury.
4. Whether the evidence supported submitting punitive damages and sustaining the punitive award under Iowa’s willful-and-wanton standard.
5. Whether the claims were time-barred and whether Deere was entitled to a pro tanto setoff based on Revere’s settlement with the former employees.
6. Whether substantial evidence supported the jury’s verdict rejecting Revere’s trade-secret misappropriation claim.

## Decision

- Affirmed the enforceability of the employees’ nondisclosure/employment agreements and upheld the jury’s verdict for Revere on tortious interference.
- Held that civil conspiracy is not an independent tort and cannot support duplicative compensatory damages for the same injury; reversed in part and remanded to eliminate double recovery.
- Affirmed the defense verdict on trade-secret misappropriation, finding substantial evidence supporting the jury’s determination.
- Upheld submission of punitive damages and left the punitive award intact based on evidence of willful and wanton disregard of Revere’s rights.
- Rejected Deere’s statute-of-limitations defense and denied a pro tanto setoff based on Revere’s settlement with Eckart and Delfino.

## Legal Principles

- A confidentiality-focused employment agreement restricting disclosure of nonpublic technical and business information may be enforceable when reasonably tailored to protect legitimate business interests and not functioning as a general restraint on competition.
- Tortious interference requires proof of a valid contract, defendant’s knowledge of it, intentional and improper interference inducing breach or disruption, causation, and damages; knowledge may be inferred from course of dealing and confidentiality markings on shared materials.
- Civil conspiracy operates as a theory for extending liability for an underlying wrongful act and does not permit additional compensatory damages beyond those attributable to the underlying tort.
- A trade-secret claimant must prove both the existence of a legally protected trade secret and misappropriation; similarity attributable to general skill and knowledge of employees may defeat misappropriation.
- Punitive damages may be submitted where evidence supports willful and wanton disregard of another’s rights, including proceeding with conduct known to induce contractual breaches.
- Settlement with other actors does not automatically reduce a judgment against a defendant absent a showing that the settlement compensated the same elements of damage for which the defendant is liable.

## Conclusion

The court largely sustained Revere’s tortious-interference and punitive-damages verdicts against Deere, affirmed the jury’s rejection of trade-secret misappropriation, and remanded to prevent duplicative compensatory recovery where conspiracy and interference rested on the same injury.


Revere Transducers, Inc. v. Deere & Co., 595 N.W.2d 751 (Iowa 1999)