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SIRQ, Inc. v. The Layton Companies, Inc., 2016 UT 30 (July 1, 2016)

Jul 1, 2016

While the appeal was pending in this case, the Supreme Court revised the common law requirements of intentional interference with economic relations in the case of Eldridge v. Johndrow,2015 UT 21. The new standard is that” [i]n the absence of any improper means, an improper purpose is not grounds for tortuous interference liability.” Although the jury instruction incorporating the improper purpose standard was correct when given, this case was pending on appeal when Eldridge was decided. The Supreme Court applied Eldridgeretroactively on the basis that “parties to other cases pending on appeal are also entitled to the benefit of such a change in the law.” Id. ¶ 6 (emphasis added).