Philip Morris, Inc. v. Emerson

In Philip Morris, Inc. v. Emerson, 235 Va. 380, 368 S.E.2d 268 (Va. 1988), the plaintiff sought recovery of lost profits to his campground business due to the negligent release of gases from the defendant's property. Citing the well-recognized principle in the Restatement of Torts which recognizes that interference with the ability to contract with third persons is too remote to permit recovery, the court refused to permit recovery of the profits plaintiffs allegedly sustained from his inability to contract with campers for overnight stays. 368 S.E.2d at 282 (citing Restatement (Second) of Tort 766 (1979)).