Ahrenholtz v. Laramie Economic Development Corp.

Summary

The Supreme Court of Wyoming reviewed summary judgment in a tortious-interference action arising from a proposed expansion of Wyoming Technical Institute. The court held that circumstantial evidence and conflicting reasonable inferences created a genuine issue of material fact regarding intentional interference with a prospective contractual relation, reversed summary judgment on that claim, and remanded for trial. It affirmed dismissal of the intentional-infliction-of-emotional-distress claim and the dismissal of Pam Ahrenholtz as a party.

Holdings

1. Summary judgment was improper because the circumstantial evidence and competing reasonable inferences created genuine issues of material fact regarding whether defendants intentionally and improperly interfered with the plaintiffs' prospective contractual relation or business expectancy with WTI.
2. Summary judgment was proper because the plaintiffs presented no evidence supporting emotional damages beyond the basic allegation that Pam Ahrenholtz was emotionally damaged; the district court's dismissal of Pam and the emotional-distress claim was affirmed.
3. A court may not resolve competing reasonable inferences, credibility questions, or evaluative judgments between rationally possible conclusions on summary judgment.

Questions Presented

1. Whether the evidence created genuine issues of material fact concerning intentional and improper interference with the plaintiffs' prospective contractual relation or business expectancy with WTI.
2. Whether the plaintiffs presented sufficient evidence of emotional distress to avoid summary judgment on the intentional-infliction-of-emotional-distress claim and to support Pam Ahrenholtz's status as a plaintiff.
3. Whether summary judgment was proper when the evidence and reasonable inferences were subject to conflicting interpretations.

Disposition

reversed_and_remanded