Leigh Furniture and Carpet Company, Plaintiff, Appellant, and Cross-Respondent v. T. Richard Isom Dba Richard’s…

Summary

The Utah Supreme Court recognized a common-law cause of action for intentional interference with prospective economic relations and adopted a rule requiring intentional interference causing injury, accompanied by an improper purpose or improper means. It held that the evidence supported liability because the defendant used groundless litigation and bad-faith contractual conduct to disrupt the plaintiff's business and economic relationships. The court also reinstated the jury's full punitive-damages award because the trial court improperly reduced it solely by applying a fixed ratio to compensatory damages. Justice Howe, concurring, agreed with the result but would not decide the broader two-issue rule because he viewed it as unnecessary to the case.