Patterson v. Meyerhofer
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| Patterson v. Meyerhofer | |
| Court | New York Court of Appeals |
|---|---|
| Citation | 97 N.E. 472 |
| Date decided | January 9, 1912 |
Facts
- Patterson = plaintiff = property seller = he didn't own the properties he was selling
- Patterson wanted to buy land at a foreclosure auction to sell to a buyer
- Meyerhofer = defendant = buyer
- Patterson signed a contract to sell 4 residential parcels in New York to Meyerhofer for $23,000
- Meyer-hofer announced that she would not honor the contract; instead, she would buy the land at the foreclosure auction herself
- Meyerhofer bought the 4 lots for $22,380 (saving $620)
Procedural History
- Patterson sued Meyerhofer seeking a breach of contract judgment for $620
- Patterson lost in the trial court & Appellate Division
Issues
Can a contracting party who intentionally causes the other party to breach a contract be held liable for damages?
Holding
Yes. A contracting party who intentionally causes the other party to breach a contract can be held liable for damages.
Meyerhofer is liable for the contract breach.Judgment
Reversed
Reasons
Judge Bartlett: The parties to a contract impliedly promise not to intentionally interfere with the other party carrying out the agreement.
Meyerhofer knew that Patterson would be buying the land parcels at the foreclosure sale. Next, she went there and bid against him. If Patteron had bought the parcels at $25,000 at the auction, then he would have lost $2,000 since his contract required him to sell the parcels to Meyerhofer for $23,000
