Environair, Inc v. Steelcase, Inc

In Environair, Inc v. Steelcase, Inc, 190 Mich App 289; 475 NW2d 366 (1991), the plaintiffs claimed that the defendant had tortiously interfered with a contract and tortitously interfered with a business relationship. Id. at 291. The defendant in Environair also brought a motion in limine seeking to limit damages. Id. Ultimately, the trial court ruled "that while Environair 3 could recover for all damages that accrued before termination of the contract . . ., recovery for damages accruing after termination . . . would be limited to nominal damages." Id. The Environair Court upheld the trial court's action, reasoning as follows: Because the nature of the relationship between Environair and defendant was one founded upon a contract that was terminable at will, we conclude that there was no cognizable tortious interference cause of action independent of that contract, because Environair's mere subjective expectation of the continuation of the contract could not justify an expectation any greater. Id. at 295.