In order to state a claim for tortious interference with existing contractual relations, a plaintiff must have alleged (1) the existence of a valid contract between plaintiff and another contracting party; (2) defendant's knowledge of that contract; (3) defendant's intentional procurement of a breach of that contract by the other party; and (4) damages.
Plaintiff sports agents brought suit against defendants, a third-party and an athlete, for interference with a contract and breach of an agency agreement. Plaintiffs claimed breach of their agreement when defendant athlete repudiated his contract with them on the exclusive right to represent him as agents to negotiate with professional football teams, while defendant third-party was claimed to have tortiously induced the athlete’s breach of the agreement. The district court dismissed plaintiffs' claims against both defendants.
Should plaintiffs’ claims against defendants for interference with a contract and breach of an agency agreement be dismissed?
The district court dismissed plaintiffs' claims against defendant third-party holding that New York's long arm statute, N.Y. C.P.L.R. 302(a)3(i), 302(a)3(ii), was inapplicable to the facts of the case. A more direct injury within the State and a closer expectation of consequences within the State was required than the indirect financial loss that resulted from the fact that the injured person resided in the State. The district court dismissed plaintiffs' interference claim with a contract against defendant athlete because plaintiffs failed to allege that defendant athlete had knowledge of the existence of other contracts. Lastly, the district court refused to enforce plaintiffs' remaining claims and defendant athlete's arbitration claim because the law did not enforce contracts that violated public policy.