## Facts

- Tata Consultancy Services employed computer consultants under fixed-term, three-year employment contracts.
- Systems International, Inc., doing business as Syntel, competed with Tata in the same consulting market.
- Syntel and associated recruiters solicited Tata’s fixed-term employees and placed them with Syntel clients before the Tata contracts expired.
- With one exception, the evidence supported that Syntel and its agents knew the employees were bound by fixed-term contracts and nonetheless induced them to leave Tata.
- Tata asserted that Syntel used the recruited employees to service the same client work and divert business from Tata.
- Tata warned Syntel that the recruiting conduct was wrongful and would lead to litigation, but the recruiting continued.

## Issues

1. Whether the summary-judgment record permitted a reasonable jury to find that Syntel and its agents tortiously interfered with Tata’s employment contracts by knowingly inducing breaches.
2. Whether a reasonable jury could find the interference “improper” or “without justification” under Michigan tortious-interference law, making summary judgment inappropriate.

## Decision

- The Sixth Circuit reversed the district court’s grant of summary judgment for defendants and remanded.
- The court held the evidence could support findings that defendants knew of the fixed-term contracts and affirmatively induced employees to breach them.
- The court further held that the “improper” or “without justification” element was fact-intensive on this record and could be resolved by a jury in Tata’s favor.

## Legal Principles

- Under Michigan law, tortious interference with contractual relations requires more than knowledge of a contract and inducement of breach; the interference must also be “improper” or “without justification.”
- Whether interference is “improper” generally depends on a multi-factor evaluation (including the nature of the conduct, motive, and competing interests in contract stability and competition) and often presents a jury question.
- On summary judgment, courts must view the evidence in the nonmovant’s favor and may not resolve contested, fact-dependent elements as a matter of law where reasonable inferences support liability.

## Conclusion

The Sixth Circuit held that Tata presented enough evidence for a jury to find that Syntel and its recruiters knowingly induced breaches of fixed-term employment contracts and did so in a manner a jury could deem improper and unjustified; summary judgment was therefore reversed and the case remanded for further proceedings.


Tata Consultancy Servs. v. Sys. Int’l, Inc., 31 F.3d 416 (6th Cir. 1994)