Citation. 1 Ch. 302 (1923).
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A union representative intentionally induced a breach of contract entered into between a chorus group manger and various theaters.
Synopsis of Rule of Law.
Intentional interference with a contractual agreement may, depending on the circumstance, be legally justified.
Facts.
A manager of a chorus group underpaid members of the chorus group for their various performances. A representative from the Actors’ Association, a performance union, persuaded owners of theaters to cancel contracts held with the manager of the chorus group until higher wagers were paid to the chorus group members. A bill of equity was brought on behalf of the manager and other owners of the group against the representative of the union to enjoin them from inducing the breaches of contract.
Issue.
Whether there is a legal justification for an intentional interference with a contractual agreement?
Held.
(Justice Russell). Yes. There may be a legal justification for an intentional interference with a contractual agreement. “[p]rima facie interference with a man’s contractual rights and with his right to carry on his business as he wills is actionable; but it is clear on the authorities that interference with contractual rights may be justified; a fortiori the inducing of other not to contract with a person may be justified.” The union was forced to take extreme measures to end the practice of underpayment of the chorus group members. These extreme measures included inducing the proprietors of theaters to either break existing contracts or to refuse to enter into contracts. The manager of the chorus group had a duty fix the problem of underpayment of the members. Therefore, even though there is no bright-line rule for such cases, the circumstances in this case allow for legal justification for interference with a contractual agreement. The action to enjoin the union from interfering with the contract is dismissed with costs.
Discussion.
This case is quite interesting because the Chancery Division makes a ruling not by using any concrete rule set out by law or in other cases, but, the court, seems to go with a moral or gut feel as to how to decide this case. The court is doubtful that the manager of the chorus group would receive any “sympathy or support [from] decent men and women.”
