Eldridge v. Johndrow

David Johndrow (defendant), after referring clients to the Eldridges' (plaintiffs') property-management business and later falling into a personal dispute with them, discovered true but embarrassing information about the Eldridges (liens, a foreclosure, an old felony conviction, and unflattering news coverage) and threatened to disclose it to referred clients unless the Eldridges retracted certain statements and returned an allegedly stolen phone; when they refused, he sent the truthful information to several clients. The Eldridges sued for tortious interference with economic relations on two theories - improper means and improper purpose; the district court dismissed the improper-means claim as based on lawful disclosure of true information, but let the improper-purpose claim proceed as a factual question.