Texas Beef Cattle Co. v. Green

In Texas Beef & Cattle Co. v. Green, 921 S.W.2d 203, 211 (Tex. 1996), the plaintiff sued for interference with a contract, and the jury found that the defendant was legally justified to interfere with the contract because the defendant was acting within his legal rights. Id. at 210. However, the trial court disregarded the jury's justification finding because it found that the defendant acted with ill will, spite, and actual malice. Id. The Texas Supreme Court rejected this formulation of the justification defense to a tortious interference claim: As we noted in Sakowitz, Inc. v. Steck, the justification defense is based on either the exercise of (1) one's own legal rights or (2) a good-faith claim to a colorable legal right, even though that claim ultimately proves to be mistaken. Sakowitz, Inc. v. Steck, 669 S.W.2d 105, 107 (Tex.1984), overruled on other grounds by Sterner v. Marathon Oil Co., 767 S.W.2d 686, 690 (Tex.1989). Thus, if the trial court finds as a matter of law that the defendant had a legal right to interfere with a contract, then the defendant has conclusively established the justification defense, and the motivation behind assertion of that right is irrelevant. Improper motives cannot transform lawful actions into actionable torts. "'Whatever a man has a legal right to do, he may do with impunity, regardless of motive, and if in exercising his legal right in a legal way damage results to another, no cause of action arises against him because of a bad motive in exercising the right.'" Montgomery v. Phillips Petroleum Co., 49 S.W.2d 967, 972 (Tex. Civ. App.-Amarillo 1932, writ ref'd). (Tex. Beef & Cattle Co., 921 S.W.2d at 211.) The Court considered the relationship between a legal right to interfere with a contract and the good faith reliance on a colorable legal right. 921 S.W.2d at 211. It explained that "if the trial court finds as a matter of law that the defendant had a legal right to interfere with a contract, then the defendant has conclusively established the justification defense, and the motivation behind assertion of that right is irrelevant." Texas Beef Cattle Co., 921 S.W.2d at 211. In other words, if the defendant conclusively proves that its interference was caused by the exercise of the defendant's own legal rights, the defendant prevails over a claim for tortious interference, without the need to submit to the jury the question of whether the defendant acted in good faith. Id. The Texas Beef Cattle Co. court went on to explain that if, on the other hand, "the defendant cannot establish such a legal right as a matter of law, it may nevertheless prevail on its justification defense if: (1) the trial court determines that the defendant interfered while exercising a colorable right, and (2) the jury finds that, although mistaken, the defendant exercised that colorable legal right in good faith." Id.