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Procedural Posture: ADA lawsuit defense California

Appellant holdover lessee sought review of the judgment for compensatory and punitive damages entered by the Superior Court of Riverside County (California) in favor of respondent lessor in respondent's actions for intentional interference with a contract, intentional interference with a prospective economic advantage, and disgorgement under the doctrine of unjust enrichment of profits.

Overview

Respondent lessor obtained judgment in an action against appellant holdover lessee for unlawful detainer. Respondent had entered into a lease agreement with another entity, of which it was a partner. Respondent then filed suit against appellant for intentional interference with a contract, intentional interference with a prospective economic advantage, and disgorgement under the doctrine of unjust enrichment of profits. The trial court entered judgment in favor of respondent for compensatory and punitive damages. On appeal, the court held that the evidence was sufficient to support the special verdicts on the intentional torts. Intention was established by evidence of appellant's decision to hold over beyond the termination of the lease, with the knowledge that such action would frustrate the legitimate contractual expectations of a specific, albeit unnamed, new lessee. That was all appellant was required to know to incur liability. Also, the trial court did not abuse its discretion by admitting evidence of the unlawful detainer action. However, the unjust enrichment award was inappropriate because respondent could obtain full redress for its losses under the tort claims.

Outcome

The court affirmed the trial court's judgment insofar as it established appellant holdover lessee's liability to respondent lessor for intentional interference with contractual relations and intentional interference with prospective economic advantage. The judgment against appellant on the theory of unjust enrichment was reversed. The judgment was further reversed on the issue of damages and remanded for retrial on that issue.