C.R. England v. Swift Transportation Company, 2019 UT 8 (Feb. 27, 2019)

On a certified question from the federal district court, the Utah Supreme Court declined an invitation to overturn St. Benedict’s Development Co. v. St. Benedict’s Hospital, 811 P.2d 194 (Utah 1991), which held that a plaintiff alleging intentional interference with contract must show that the defendant interfered through “improper means.”  Acknowledging that St. Benedict’s had misinterpreted prior precedent, the court nonetheless concluded that the resulting “improper means” requirement was both legally sound and firmly embedded in Utah law.  The court went on to clarify that “improper means” is defined in this context “as conduct contrary to law—such as violations of statutes, regulations, or recognized common-law rules—or the violation of an established standard of a trade or profession.”