Quintana v. First Interstate Bank’s Empirical Analysis
1987
Citation profile
6 federal appellate · 4 district · 4 state decisions
How this case has been cited
Cited by 22 later decisions — most recently August 2014
6 federal appellate · 4 district · 4 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on H. T. Coker Construction Co. v. Whitfield Transportation, Inc. · M & M Rental Tools, Inc. v. Milchem, Inc. · Wolf v. Perry · Bottijliso v. Hutchison Fruit Co. · Williams v. Ashcraft
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 22 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[A] plaintiff must demonstrate that the defendant 'interfered [with contractual relations] with an improper motive or by improper means, or acted without justification or privilege.'”
2 later decisions quote this exact passage“The mere refusal to deal with a party cannot support a claim for tortious interference with contractual relations. Restatement (Second) of Torts § 766 comment b (1979). As long as the Bank merely refused to enter into business relations with plaintiffs and left Guardian to make its own decision on what to do about the Bank’s refusal, plaintiffs have no cause of action. Restatement, supra, comment 1. As stated in Restatement of Torts § 762 (1939): One who causes intended or unintended harm to another merely by refusing to enter into a business relations with the other or to continue a business relation terminable at his will in not liable for that harm if the refusal is not (a) a breach of the actor’s duty to the other arising from the nature of the actor’s business or from a legislative enactment, or (b) a means of accomplishing an illegal effect on competition, or (c) part of a concerted refusal by a combination of persons of which he is a member. This section was omitted from the Restatement, supra, Section 766, because the American Law Institute felt that the principles stated were more appropriately located in the field of trade regulation than in tort. Restatement, supra, Division 9, Introductory Note, at 2. It is still a viable statement of the law and continues to be cited by courts. E.g. Vermont Nat'l Bank v. Dowrick, 144 Vt. 504, 512 , 481 A.2d 396 , 400 n. 1 (1984), and cases cited therein. In our case, none of the above three conditions can be met, and the Bank was”
1 later decision quote this exact passage“breach of a contract with a third party is not the sort of improper means that has been held sufficient to support a claim of tortious interference with contractual relations”
1 later decision quote this exact passage
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.