Prudential Insurance Co. of America v. Financial Review Services, Inc

In Prudential Insurance Co. of America v. Financial Review Services, Inc., 29 S.W.3d 74 (Tex. 2000), the Court acknowledged that "we have never enumerated the elements of a cause of action for tortious interference with prospective contracts" but concluded that it was not necessary to do so to reach a decision in that case. Id. at 78. There, the plaintiff had contracted with hospitals to audit their records to determine whether all services and supplies furnished to patients had been billed, and to invoice insurers for previously unbilled items. Id. at 76. When the defendant health insurer complained to its insureds and to the hospitals that the plaintiff was overbilling, the hospitals terminated their agreements with the plaintiff. The plaintiff sued the insurer for intentional interference with the plaintiff's contracts with the hospitals and appeared to allege interference with prospective contracts as well. Id. at 78. The Court concluded that the plaintiff had adduced evidence that the defendant had falsely disparaged the plaintiff's business that precluded summary judgment for the defendant. Prudential Ins., 29 S.W.3d at 80-83.