White Plains Coat & Apron Co., Inc. v. Cintas Corp.

White Plains Coat & Apron (plaintiff) held five-year exclusive service contracts with clients; competitor Cintas (defendant), with no prior economic relationship to those clients, contracted with many of them during the exclusivity period, causing them to breach. White Plains sued for tortious interference; Cintas claimed it did not know of the existing contracts and asserted a generalized economic-interest defense as a competitor seeking business, and the district court granted Cintas summary judgment. On appeal, the Second Circuit certified to the New York Court of Appeals whether a generalized economic interest in soliciting business is a defense when the alleged tortfeasor had no prior economic relationship with the breaching party.

Whether a generalized economic interest in soliciting business constitutes a defense to tortious interference with an existing contract when the alleged tortfeasor has no previous economic relationship with the party who breached.