Corrigan v. Baird

46 Va. Cir. 511, 1996 Va. Cir. LEXIS 512
CourtLoudoun County Circuit Court
DecidedMarch 11, 1996
DocketCase No. (Law) 17282
StatusPublished

This text of 46 Va. Cir. 511 (Corrigan v. Baird) is published on Counsel Stack Legal Research, covering Loudoun County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Corrigan v. Baird, 46 Va. Cir. 511, 1996 Va. Cir. LEXIS 512 (Va. Super. Ct. 1996).

Opinion

BY JUDGE THOMAS D. HORNE

This case is before the Court on the demurrers of the defendants to the Motion for Judgment. Plaintiffs seek to hold the various defendants liable for damages based upon conduct which they suggest is both tortious and violative of their contractual obligations. Plaintiffs are Mark R. Corrigan and two business entities of which Mr. Corrigan is principal officer and stockholder: Chesapeake Classics, L.L.C., t/a Williams and Sons, a Maryland Limited Liability Company, and Virginia American Management Company, t/a Harper’s Ferry Arms Co., a Virginia Corporation. The thirty-one individual originally-named defendants have at one time or another had a relationship to the corporate defendant, North-South Skirmish Association, Inc. Certain of the defendants have been nonsuited from the case.

The pleadings suggest that North-South Skirmish Association, Inc., is involved in the sponsoring of marksmanship competitions. Individuals participating through member organizations are required to use firearms, or parts thereof, such as those manufactured and sold by Williams and Sons and Harper’s Ferry Arms Co. Mark R. Corrigan submits that, while he no longer participates in events sponsored by North-South, his inability to participate has resulted from misconduct of the Association and various persons active in its affairs. The defalcations and acts of misconduct for which the plaintiffs seek [512]*512damages are characterized by a breach of contract and tortious interference with the business of the various plaintiffs.

The four counts of the Motion for Judgment relate to various incidents which have occurred over the last twenty years.

Count I is concerned with certain action taken by the Board of Directors of the North-South Skirmish Association in 1993. Several of the named defendants were members of the Board at that time. Plaintiffs suggest that the individual defendants named in Count I, acting with malice and with the intent to injure Corrigan and Williams, caused the North-South Skirmish Association to deny approval for a gun barrel manufactured by Williams. Approval of the barrel was a prerequisite to its integration into firearms used by members at competitive matches sponsored by the corporate defendant. Corrigan and Williams contend that they lost business as a result of such action by the individuals involved in the denial of the approval of the barrel.

Count II of the Motion for Judgment alleges tortious interference with the business of Corrigan, Williams, and Harper’s Ferry by certain of the individual defendants who, they suggest, participated in fabricating and acting upon a charge of cheating leveled against Mr. Corrigan by the North-South Skirmish Association. The cheating charge, and subsequent disciplinary action taken against Corrigan by the Board of Directors of the Association, arose out of a marksmanship activity in which Mr. Corrigan participated in the summer of 1992. Because of the relationship of Corrigan to Williams and Harper’s Ferry and of the good standing of Mr. Corrigan among his peers, the plaintiffs claim that the unfounded cheating charge and subsequent actions of the Association adversely affected the good will, standing, reputation, credit, and property of all three plaintiffs.

In Count III, the Plaintiffs contend that certain of the individual defendants and the North-South Skirmish Association breached an agreement reached with Mr. Corrigan in 1976 in the settlement of a suit between Corrigan, Harper’s Ferry, and the Association. At issue is the action of the Association in sanctioning Mr. Corrigan subsequent to his having been informed that he had “satisfied” the penalties imposed by a disciplinary panel created pursuant to the agreement. The subsequent sanction involved the deletion of certain points accumulated by Mr. Corrigan in his pursuit of the highest accolade of the Association, the Distinguished Skirmish Shooter Award. Plaintiffs assert that the defendants breached their agreement when they elected to impose an additional sanction to that which both parties had agreed to accept many years earlier, all to his injury and damage.

Lastly, in Count IV of the Motion for Judgment, the Plaintiffs contend that the actions of the Directors of North-South in banning him from future [513]*513competitions of the Association and in stripping him of the points necessary to attain the Distinguished Skirmish Shooter Award have injured the business relationship of the various plaintiffs with the skirmishers who participate in Association activities. They suggest that the injury caused to the reputation of Mr. Corrigan and its resultant effect upon the good will of the corporate plaintiffs constitutes a compensable claim for lost profits. Because he has been wrongfully barred from future activities of the Association, Mr. Corrigan contends that he can no longer maintain the kind of personal relationship necessary to the carrying on of the business of Williams and Harper’s Ferry.

Three of the counts of the Motion for Judgment are founded upon a theory of recovery styled “Tortious Inference with ... Business.” A fair reading of the pleadings would lead one to believe that what plaintiffs seek is to recover for a tortious interference with past contractual relations or a business expectancy. The Supreme Court has outlined the elements of such tort as:

(1) the existence of a valid contractual relationship or business expectancy;
(2) knowledge of the relationship or expectancy on the part of the interferer;
(3) intentional interference inducing or causing a breach or termination of the relationship or expectancy; and
(4) resultant damage to the party whose relationship or expectancy has been disrupted.

Chaves v. Johnson, 230 Va. 112, 120 (1985) (authority omitted). In the case of a contract terminable at will, the plaintiff must demonstrate in addition that improper methods were used. Duggin v. Adams, 234 Va. 221 (1987). Malice is not a requisite element of the claim. Chaves, supra, at 121. The tort is:

an intentional wrong to the property rights of another, accomplished by words, not defamatory in themselves, but employed in pursuance of a scheme designed wrongfully to enrich the speaker at the expense of the victim.

Id. at 122.

In addition, a cause of action for interference with a prospective business or economic advantage exists, even though no breach of contract has occurred. The Supreme Court has enumerated the elements of that tort as:

[514]*514(1) the existence of a business relationship or expectancy, with a probability of future economic benefit to [the] plaintiff;
(2) defendants’s knowledge of the relationship or expectancy;
(3) a reasonable certainty that absent defendant’s intentional misconduct, plaintiff would have continued in the relationship or realized the expectancy; and
(4) damage to the plaintiff.

Glass v. Glass, 228 Va. 39, 52 (1984) (citation omitted).

The Motion for Judgment should clearly identify which of the possible theories of recovery the plaintiffs intend to rely upon in Counts I, II, and IV and then allege sufficient facts to justify recovery as to the named defendants.

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Related

Glass v. Glass
321 S.E.2d 69 (Supreme Court of Virginia, 1984)
Chaves v. Johnson
335 S.E.2d 97 (Supreme Court of Virginia, 1985)
Duggin v. Adams
360 S.E.2d 832 (Supreme Court of Virginia, 1987)

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Bluebook (online)
46 Va. Cir. 511, 1996 Va. Cir. LEXIS 512, Counsel Stack Legal Research, https://law.counselstack.com/opinion/corrigan-v-baird-vaccloudoun-1996.