Calbom v. Knudtzon

Citation. 396 P.2d 148 (Wash. 1964)

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Citation396 P.2d 148 (Wash. 1964)

Brief Fact Summary.

Calbom filed suit against Knudtzon after Knudzton influenced Henderson to hire a different probate attorney for her deceased husband’s probate proceedings.

Synopsis of Rule of Law.

A person is liable to a plaintiff if they intentionally induce a third party not to do business with the plaintiff.

Points of Law - Legal Principles in this Case for Law Students.

Ill will, spite, defamation, fraud, force, or coercion, on the part of the interferor, are not essential ingredients, although such may be shown for such bearing as they may have upon the defense of privilege.

View Full Point of Law

As executrix of her husband’s will, Henderson hired Calbom as her lawyer for the probate proceedings and Knudtzon as an accountant for her husband’s estate. Knudtzon indicated to Henderson that Calbom was a poor choice for a probate attorney. At Knudtzon’s recommendation, Henderson hired another attorney. Calbom sued Knudtzon and the trial court granted judgment to Calbom.

Issue.

Whether a person is liable to a plaintiff if they intentionally induce a third party not to do business with the plaintiff?

Held.

Yes. The trial court judgment is affirmed. Knudtzon intentionally interfered with Calbom’s relationship with Henderson, causing the termination of the contract.

Discussion.

A person is liable to a plaintiff if they intentionally induce a third party not to do business with the plaintiff. The plaintiff must demonstrate: (1) the existence of a contractual relationship, (2) the defendant’s knowledge of the contractual relationship, (3) the defendant’s interference with the relationship and a breach of contract, and (4) damages.