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J.D. Edwards & Co. v. Podany

United States Court of Appeals for the Seventh Circuit

168 F.3d 1020 (7th Cir. 1999)

Relevant factsFree

SNE hired J.D. Edwards (Edwards) (plaintiff) for software services after rejecting a competing product, BPCS, for lacking a needed feature. SNE then hired consultant Randy Podany (defendant) to review the Edwards project; Podany advised SNE to scrap the Edwards project and switch to BPCS after all, even though BPCS was the only software he was personally familiar with. SNE followed his advice, the BPCS software then failed, and Edwards sued Podany for inducing SNE's breach of its contract with Edwards. At trial, evidence showed Podany was secretly angling to get a job with SNE's parent company and drum up business for his own employer, and his credibility was impeached. The jury found for Edwards, and Podany appealed.

IssueFree

Whether a consultant is liable for inducing a breach of contract when his motive for giving the advice was personal gain rather than a good-faith professional judgment.

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