Wal-Mart Stores, Inc. v. Sturges
Supreme Court of Texas
52 S.W.3d 711 (2001)
Sturges (plaintiff) was negotiating to lease a vacant lot to Fleming Foods when Wal-Mart (defendant) told Fleming Foods it wanted to buy the lot to expand its own store and would relocate elsewhere if it could not, causing Fleming Foods to abandon the Sturges negotiations rather than build without a neighboring Wal-Mart; a jury found Wal-Mart's interference intentional and unjustified, awarding Sturges substantial actual and punitive damages, and the court of appeals affirmed the actual damages while ordering retrial on punitive damages.
Whether, to maintain an action in Texas for tortious interference with a prospective contractual relation, a plaintiff must prove it was harmed by conduct that was independently tortious or unlawful.