J.J. Industries, LLC v. Bennett, 119 Nev. 269

Summary

The Supreme Court of Nevada defines the knowledge and intentional-act elements of an intentional interference with contractual relations claim. The court holds that Hale Bennett's conduct was not supported by sufficient evidence of an intent to induce breach and reverses the judgment against him. It also reduces the breach-of-contract damages against Norman Kaye from $598,000 to $98,000 and remands for entry of the reduced award.

Holdings

1. A plaintiff may establish the knowledge element by showing that the defendant knew of the existing contract or, at minimum, knew facts from which the existence of the contract could reasonably be inferred.
2. Mere knowledge of an existing contract and entry into an agreement with a contracting party are insufficient to establish intentional interference. The plaintiff must prove that the defendant intended to induce the other party to breach the contract, requiring evidence of the defendant's motive or purpose.
3. The evidence was insufficient to support liability against Hale Bennett for intentional interference with J.J. Industries' contractual relations.
4. Damages for breach of a contract to sell real estate are the difference between the contract price and the property's market value on the date of breach; an award based on speculative evidence cannot stand.

Questions Presented

1. Whether there was sufficient evidence that Hale Bennett knew of J.J. Industries' contract with Kaye.
2. Whether knowledge of an existing contract, together with entering into a competing purchase agreement, establishes the intentional acts required for intentional interference with contractual relations.
3. Whether the jury's $598,000 breach-of-contract damages award against Kaye was legally supportable or speculative.
4. Whether the district court erred in dismissing Kay Bennett and J.J. Industries' specific-performance claim.

Disposition

reversed_and_remanded