46 N.Y.2d 276 (1978)
To establish a claim for tortious interference with contractual relations, the interference must be intentional, not merely negligent or incidental to another legitimate business purpose.
Summary
Alvord & Swift, a subcontractor, sued New York Telephone, the owner of a construction project, alleging tortious interference with its subcontract due to delays. The New York Court of Appeals affirmed the lower court’s grant of summary judgment to New York Telephone. The court held that while a plaintiff’s submissions can be considered on a summary judgment motion even if the pleadings are deficient, the plaintiff failed to present evidence of intentional interference by New York Telephone. The interference, at most, was incidental to New York Telephone’s business purpose and thus did not meet the standard for tortious interference.
Facts
New York Telephone contracted with Stewart M. Muller Construction Co. for renovations. Alvord & Swift subcontracted with Muller to perform HVAC work. The prime contract stipulated no contractual relationship between the owner (New York Telephone) and any subcontractor. Alvord’s subcontract incorporated the terms of the prime contract and granted Alvord the same rights against Muller as Muller had against New York Telephone. Construction was significantly delayed, increasing Alvord’s expenses. Alvord sued New York Telephone alleging, in its sixth cause of action, that the owner failed to adequately supervise the project, disrupting Alvord’s work.
Procedural History
The Supreme Court, Special Term, granted summary judgment to New York Telephone, interpreting Alvord’s sixth cause of action as a breach of contract claim barred by lack of privity. Alvord appealed, arguing the claim was for tortious interference. The Appellate Division affirmed. Alvord appealed to the New York Court of Appeals.
Issue(s)
Whether summary judgment can be granted against a plaintiff who, despite pleading deficiencies, presents evidence of a cause of action in their submissions.
Whether a tort cause of action for interference with contractual relations is established when the interference is not intentional, but incidental to a legitimate business purpose.
Holding
Yes, but summary judgment was still properly granted in this case. Modern principles of procedure do not permit an unconditional grant of summary judgment against a plaintiff who, despite defects in pleading, has in his submissions made out a cause of action.
No, because the interference must be intentional and unjustified to constitute tortious interference with contractual relations.
Court’s Reasoning
The court reasoned that on a motion for summary judgment, courts should look beyond the pleadings to determine the true nature of the case. While a deficient pleading is not necessarily fatal, the plaintiff must still demonstrate a triable issue of fact. In this case, Alvord argued that New York Telephone tortiously interfered with its subcontract. The court acknowledged that intentional interference with contractual relations is a recognized tort. However, it emphasized that the interference must be intentional, not merely a consequence of negligence or incidental to a lawful purpose.
The court found that Alvord failed to produce evidence that New York Telephone intentionally and unjustifiably interfered with Alvord’s work. The court stated, “There has never been any indication that an intentional tort was committed in the sense of an intention to harm plaintiff without economic or other lawful excuse or justification.” The court distinguished cases where a property owner may have a contractual obligation not to interfere, stating that such obligations arise from privity, which was absent here. The court concluded that without evidence of intentional interference, summary judgment was proper. As the court held, “Statements in a pleading shall be sufficiently particular to give the court and parties notice of the transactions, occurrences, or series of transactions or occurrences, intended to be proved and the material elements of each cause of action or defense.”