Westside Center Associates v. Safeway Stores

In Westside Center Associates v. Safeway Stores (1996) 42 Cal.App.4th 507, the court held that the requirement that the plaintiff plead and prove that a business relationship contained the "probability of future economic benefit" precluded application of the tort to "hypothetical relationships" not developed at the time of the allegedly tortious acts. (Westside, at p. 522.) The Westside court rejected the plaintiff's claim the defendant interfered with its lost "opportunity" to sell a piece of property for its market value, concluding the interference tort applies to interference with existing noncontractual relations that hold the promise of future economic advantage. (Id. at p. 524.) "In other words, it protects the expectation that the relationship eventually will yield the desired benefit, not necessarily the more speculative expectation that a potentially beneficial relationship will eventually arise." (Ibid.)