White Plains Coat & Apron Co. is a New York–based linen rental business. Cintas Corp. is a nationwide business that rents similar products. White Plains had five-year exclusive contracts with some of its customers. As a result of Cintas’s soliciting of business, dozens of White Plains’ customers breached their contracts and entered into rental agreements with Cintas. White Plains demanded that Cintas stop its solicitation of White Plains customers. Cintas refused. White Plains filed a suit in a federal district court against Cintas, alleging wrongful interference with existing contracts. Cintas argued that it had no knowledge of any contracts with White Plains and had not induced any breach. The court dismissed the suit, ruling that Cintas had a legitimate interest as a competitor to solicit business and make a profit. White Plains appealed to the U.S. Court of Appeals for the Second Circuit.
(a) What are the two important policy interests at odds in wrongful interference cases? When there is an existing contract, which of these interests should be accorded priority?
(b) The U.S Court of Appeals for the Second Circuit asked the New York Court of Appeals to answer a question: Is a general interest in soliciting business for profit a sufficient defense to a claim of wrongful interference with a contractual relationship? What do you think? Why?