United Nat’l Maint. v. San Diego Convention Ctr.

Under California law even though a party has an economic interest in a contractual relationship, that party can still be found liable for any intentional interference with that contract.

United National Maintenance (“UNM”) brought action against the San Diego Convention Center Corporation (“SDC”) for intentional interference with a contractual relationship, antitrust violations, and intentional interference with prospective economic advantage. A district court jury found in favor of UNM for intentional interference with a contractual relationship claim but hung on the other two claims. Following SDC’s motion for judgment as a matter of law, the district court ruled in SDC’s favor for all three claims following which, UNM filed a timely appeal. The Ninth Circuit held that SDC could be liable for intentional interference with a contractual relationship based on its implementation of new policies because, under California law, even though a party has an economic interest in a contractual relationship that party can still be found liable for any intentional interference with that contract. The panel also found that the district court erred by not providing instructions that interpreted the terms of the contracts being reviewed and that SDC is protected from liability under federal antitrust laws. AFFIRMED in part and REVERSED in part.