## Facts

- Edward C. Tuttle operated a barbershop in Howard Lake, Minnesota, for over ten years and alleged it was profitable and supported his family.
- Cassius M. Buck, a wealthy banker with influence in the community and no legitimate interest in barbering, allegedly sought to destroy Tuttle’s business and drive him out of the village.
- Tuttle alleged Buck persistently attempted to divert Tuttle’s customers through false reports, personal solicitations, threats of Buck’s displeasure, and other wrongful devices.
- Buck allegedly established and furnished a barbershop and hired a skilled barber to operate it.
- Tuttle alleged Buck did so not to compete for Buck’s own business benefit, but solely to injure Tuttle and ruin his trade.
- Tuttle alleged the conduct caused his business to be ruined, and he sued for damages.

## Issues

1. Whether a complaint states a cause of action when it alleges the defendant established and operated a competing business and used personal influence to divert customers solely to injure the plaintiff, without any legitimate business purpose.

## Decision

- The trial court overruled Buck’s general demurrer for failure to state a claim.
- The Minnesota Supreme Court affirmed, holding the complaint stated a cause of action.
- On demurrer, the court accepted the pleaded facts as true and asked whether those facts, if proved, constituted an actionable wrong.
- Two justices dissented.

## Legal Principles

- Intentional injury to another’s business without justifiable cause may be actionable.
- Competition is generally lawful: a person may seek to attract a rival’s customers to gain trade for oneself, absent contract, so long as unlawful means are not used.
- Conduct that takes the form of “competition” but is undertaken solely to injure a rival, with no legitimate business end, may constitute tortious interference with business.
- A lawful act may be actionable where it is done intentionally and solely to harm another’s business and is not connected to any legitimate interest of the actor.

## Conclusion

The court held that allegations a wealthy and influential defendant opened and supported a rival barbershop, not to advance any legitimate competitive interest but solely to ruin the plaintiff’s business, were sufficient to state a tort claim for wrongful interference with business.


Tuttle v. Buck, 107 Minn. 145, 119 N.W. 946 (Minn. 1909)