Western Blue Print Co. v. Roberts

Summary

The Missouri Supreme Court reviewed a jury verdict against former employees and affiliated entities involving alleged breach of fiduciary duty, tortious interference with a business expectancy, computer tampering, and civil conspiracy. The court held that the employee, an at-will division vice president who was neither an officer nor director and was not subject to a non-compete agreement, did not owe Western Blue a fiduciary duty under the circumstances. The judgment was affirmed in part, reversed in part, and remanded.

Holdings

1. An at-will employee who is not an officer, director, partner, or member of a limited liability company, is not subject to a noncompete agreement, and does not have a qualifying confidential relationship does not owe the employer a fiduciary duty under the circumstances presented.
2. Western Blue presented substantial evidence of a valid business expectancy in renewal of the university contract and of improper means used by Myrna to interfere with that expectancy; the denial of directed verdict and JNOV was proper.
3. The evidence permitted a reasonable inference that Myrna knowingly deleted and copied Western Blue's computer data without authorization, supporting the computer-tampering verdict.
4. The evidence supported a civil-conspiracy claim against Mel because he acted with Myrna pursuant to an unlawful objective and committed acts in furtherance of tortious interference with Western Blue's business expectancy.
5. The circuit court did not abuse its discretion by awarding Western Blue $224,489.18 in attorneys' fees attributable to the computer-tampering claim after attempting to segregate fees from other claims.

Questions Presented

1. Whether Myrna Roberts, an at-will division vice president who was neither an officer nor director and was not subject to a noncompete agreement, owed Western Blue a fiduciary duty.
2. Whether Western Blue presented sufficient evidence of a valid business expectancy and improper means to support its tortious-interference claim concerning renewal of the University of Missouri contract.
3. Whether substantial evidence supported the computer-tampering verdict based on deletion and copying of Western Blue's electronic data.
4. Whether substantial evidence supported the civil-conspiracy verdict against Mel Roberts.
5. Whether the circuit court abused its discretion by awarding attorneys' fees for the computer-tampering claim without improperly awarding fees for unrelated claims.

Disposition

reversed_and_remanded