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Youst v. Longo - 43 Cal. 3d 64, 233 Cal. Rptr. 294, 729 P.2d 728 (1987)

Rule:

The five elements for intentional interference with prospective economic advantage are: (1) an economic relationship between the plaintiff and some third party, with the probability of future economic benefit to the plaintiff; (2) the defendant's knowledge of the relationship; (3) intentional acts on the part of the defendant designed to disrupt the relationship; (4) actual disruption of the relationship; and (5) economic harm to the plaintiff proximately caused by the acts of the defendant.

Facts:

Plaintiff Harlan Youst entered his standardbred trotter horse, Bat Champ, in the eighth harness race at Hollywood Park in Inglewood, California. Also entered in the race was The Thilly Brudder, driven by defendant, Gerald Longo. During the race, Longo allegedly drove The Thilly Brudder into Bat Champ's path and struck Bat Champ with his whip, thereby causing the horse to break stride. Bat Champ finished sixth while The Thilly Brudder finished second. The Board reviewed the events of the race and disqualified The Thilly Brudder, which moved Bat Champ into fifth place, entitling plaintiff to a purse of only $5,000. Youst filed a complaint for damages against defendant in the Los Angeles Superior Court.

Issue:

Could there be a cause of action for interference or conspiracy to interfere with prospective economic advantage with regard to a sporting event?

Answer:

No

Conclusion:

The court held that losing the chance to win a horse race did not present a basis for tort liability for interference with prospective economic advantage because the nature of the sporting event was too speculative. The court held that no such tort cause of action was available in the context of any sporting event. The court further held that the court of appeal erred in concluding that a conspiracy claim was actionable because the underlying tort claim was unavailable in the sporting event context. The court also held that the board did not have jurisdiction to award general tort damages.

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