Bacon v. St. Paul Union Stockyards Company

Supreme Court of Minnesota · 1924 · Torts
201 N.W. 326 (1924)
Updated
TortsInterference with employmentIntentional interference with contract relationstortious interferenceemploymentcontract relationswrongful exclusiondemurrer

Facts

Defendant operated a livestock yard with facilities for loading, unloading, caring for, buying, selling, and dealing in livestock. Plaintiff alleged that since August 1, 1918, he had continually worked in and about defendant's yards in buying, selling, and dealing in livestock, and that he was employed by Drover Livestock Commission Company at a salary of $200 per month. Plaintiff further alleged that on July 3, 1923, defendant wrongfully, unlawfully, and willfully excluded him from the stockyards, barred him from carrying on his occupation there, and forbade others from employing him in or about the yards. He alleged that he was able to continue that employment at the same salary but for defendant's conduct and that defendant could impose only reasonable and nondiscriminatory rules and regulations.

Issue

Does a complaint state a cause of action when it alleges that a defendant wrongfully, willfully, and unlawfully excluded the plaintiff from the defendant's premises and prevented others there from employing him, thereby preventing plaintiff from continuing his steady employment?

Rule

Wrongful interference with the contract relations of others causing a breach is a tort. A complaint states a cause of action when it alleges that the plaintiff had steady employment and that the defendant wrongfully, willfully, and unlawfully prevented the plaintiff from continuing in that employment.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.
Lena Ortiz worked for three years as a salaried produce broker for River Bend Commission House inside a privately operated wholesale market in Chicago. The market operator then deliberately barred Lena from entering the market and instructed all commission tenants not to employ her there, after which River Bend stopped using her because she could no longer work on site.

If Lena sues the market operator and alleges those facts, which is the best argument that her complaint survives a demurrer for failure to state a claim?

Explanation. The governing rule is that wrongful interference with the contract relations of others causing a breach is a tort. A complaint is sufficient when it alleges steady employment and that the defendant wrongfully, willfully, and unlawfully prevented the plaintiff from continuing in that employment. The majority treated those allegations as enough at the pleading stage, without requiring a statutory violation or proof at that stage.