Sunday, December 1, 2013

Rite Aid Corp. v. Lake Shore Investors case brief

Rite Aid Corp. v. Lake Shore Investors case brief summary
471 A.2d 735 (1984)


CASE SYNOPSIS
Petitioner corporation sought review of the judgment from the Court of Special Appeals (Maryland), which found that the trial court erred in limiting the evidence of damages to the benefit of the bargain and that respondent investors should have been permitted to prove such damages as would have reasonably flowed from the tortious contractual interference by petitioner. The issue raised was how the damages were supposed to have been measured.

CASE FACTS
Following the judgment that found that trial court erred in limiting the evidence of damages in an action for injurious falsehood and tortious interference with a land sale, petitioner corporation sought review.

DISCUSSION

  • On review, the issue presented was whether the trial court applied the correct measure of damages. 
  • The court affirmed the judgment, holding that the trial court did not apply the correct measure of damages to respondent investors' claim of injurious falsehood and tortious interference with a land sale contract.
  • The court found that the trial court erred in failing to distinguish between damages which may be recovered in an action for interference with a contract and those which may be recovered in an action of disparagement of real property. 
  • Further, the trial court's limitation as to both torts of evidence pertaining to damages measured under benefit of bargain was erroneous. 
  • The court reasoned that the trial court's limitation was with the view that in no event were damages recoverable except those arising from losses calculated under the benefit of bargain test. 
  • The court concluded that this was not necessarily true.

CONCLUSION
The judgment that found that the trial court did not apply the correct measure of damages to respondent investors' claim of injurious falsehood and tortious interference with a land sale contract was affirmed. The court held that the trial court's limitation as to both torts of evidence pertaining to damages measured under the contract method benefit of bargain was erroneous.

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