Catskill Development, L.L.C. v. Park Place Entertainment Corp.

345 F. Supp. 2d 360, 2004 U.S. Dist. LEXIS 23788, 2004 WL 2699974
CourtDistrict Court, S.D. New York
DecidedNovember 15, 2004
Docket00 CIV.8660(DM)
StatusPublished
Cited by5 cases

This text of 345 F. Supp. 2d 360 (Catskill Development, L.L.C. v. Park Place Entertainment Corp.) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Catskill Development, L.L.C. v. Park Place Entertainment Corp., 345 F. Supp. 2d 360, 2004 U.S. Dist. LEXIS 23788, 2004 WL 2699974 (S.D.N.Y. 2004).

Opinion

MEMORANDUM DECISION AND ORDER REVISITING THE COURT’S PREVIOUS FINDING CONCERNING EVIDENCE OF “WRONGFUL MEANS;” REINSTATING THE JUDGMENT AND DIRECTING THE CLERK OF THE COURT TO ENTER JUDGMENT FOR DEFENDANT

MCMAHON, District Judge.

On October 7, 2003, this Court issued a Memorandum Decision and Order granting plaintiffs’ motion to vacate this Court’s decision granting summary judgment to defendant on plaintiffs’ claim of intentional interference with prospective business relations. This court had jurisdiction to enter the order because the United States Court of Appeals for the Second Circuit— where an appeal from this court’s final judgment was pending — relinquished jurisdiction so that I could reopen the record and reconsider my previous finding that plaintiffs had failed to adduce evidence of “wrongful means,” necessary predicate to establishing their claim of intentional interference. In the October 7 decision and order, I directed the parties to conduct limited discovery on a very tight time line and to present briefs limited to the subject of “wrongful means” so that I could decide the issue and get the case back to the Second Circuit.

An intervening event extended the schedule. On November 21, 2003, the Second Circuit certified to the New York Court of Appeals, in case entitled Carvel Corporation v. Noonan, 350 F.3d 6 (2d Cir.2003), the question of whether a franchisee had a valid claim for interference with prospective economic relations. The New York Court of Appeals accepted the certified question in order to clarify certain language in its controlling case, Guard-Life Corp. v. S. Parker Hardware Mfg. Corp., 50 N.Y.2d 183, 428 N.Y.S.2d 628, 406 N.E.2d 445 (1980) and NBT Bancorp. Inc. v. Fleet/Norstar Financial Group, Inc., 87 N.Y.2d 614, 641 N.Y.S.2d 581, 664 N.E.2d 492 (1996), concerning what a plaintiff must show “where there has been no breach of an existing contract, but only interference with prospective contract rights...” NBT, supra, 87 N.Y.2d at 621, 641 N.Y.S.2d 581, 664 N.E.2d 492. Because the answer to that question could have proved dispositive of the question I had reclaimed this case to resolve — whether plaintiffs had raised a genuine issue of material fact concerning defendant’s alleged use of “wrongful means” to induce the St. Regis Mohawk Tribe to enter into an exclusive casino development agree *362 ment with Park Place — I put everything on hold pending the outcome of Carvel.

On October 14, 2004, the New York Court of Appeals handed down its decision in Carvel v. Noonan, 3 N.Y.3d 182, 818 N.E.2d 1100 (2004). I have read that decision and the briefs of the parties commenting thereon. To my great dismay, I fear I agree with plaintiffs that Judge Robert S. Smith’s opinion does not set forth the sort of “bright line” test for what constitutes “wrongful means” that I was hoping for. I must, therefore, wrestle with the issue I started out to address upon vacatur of the original judgment. Judge Smith’s opinion does, however, offer me some guidance on the point, which I gratefully accept. 1

I. Carvel and the Concept of “Wrongful Means” in Connection with the Tort of Interference with Prospective Economic Relations

The second cause of action in the complaint in this action (the only claim with which we are concerned) alleges that Park Place intentionally interfered with plaintiffs’ non-contractual but prospective business advantage with the St. Regis Mohawk Tribe in connection with the casino it proposed to develop at the Monticello Raceway in Sullivan County, New York. 2

*363 Under New York law, a third party’s interference with a prospective business relationship that has not yet been reduced to contract is actionable only in limited circumstances. To prevail on such a claim, a plaintiff must show that the defendant’s conduct was “culpable.” That can mean one of two things:

(1) The defendant acted for the sole purpose of inflicting intentional harm on the plaintiffs. Actions taken to promote the economic interest of the defendant are not taken for the sole purpose of harming the plaintiff; or
(2) The defendant effected the interference by “wrongful means.”

For many years, it appeared that “wrongful means” was limited to the commission of acts that were either criminal or independently tortious. However, in Guard-Life, 50 N.Y.2d 183, 428 N.Y.S.2d 628, 406 N.E.2d 445, the New York Court of Appeals referred approvingly to Section 768 of the Restatement [Second] of Torts, the comments to which described “wrongful means” to include not only criminal acts, but “physical violence, fraud or misrepresentation, civil suits and criminal prosecutions, and some degrees of economic pressure, ... [but not] persuasion alone although it is knowingly directed at interference with the contract.” Predictably, a question arose: since a party was privileged to attempt to procure business for itself as long as it did not interfere with a bona fide contract, what could possibly be meant by “some degrees of economic pressure?” Economic pressure was all but guaranteed in any situation where a competitor tried to step between his competitor and a third party with whom both wished to deal. What would make such economic pressure wrongful?

My hope was that the New York Court of Appeals would answer this question definitively in Carvel. It did not.

Carvel was a suit brought by several Carvel franchisees against their franchisor, alleging that Carvel’s distribution of its products through supermarkets that competed with the plaintiff-franchisees was both tortious and a violation of their franchise rights. Among the claims asserted was one for “interference with prospective economic relations” between the plaintiff franchisees and their customers. The gravamen of the claim was that Carvel induced persons who would otherwise have bought their ‘ ice cream from Carvel to purchase Carvel products in supermarkets. The New York Court of Appeals concluded that this claim was foreclosed by New York law.

The Carvel

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Bluebook (online)
345 F. Supp. 2d 360, 2004 U.S. Dist. LEXIS 23788, 2004 WL 2699974, Counsel Stack Legal Research, https://law.counselstack.com/opinion/catskill-development-llc-v-park-place-entertainment-corp-nysd-2004.