This section is from the book "The Law Of Contracts", by William Herbert Page. Also available from Amazon: Commercial Contracts: A Practical Guide to Deals, Contracts, Agreements and Promises.
In jurisdictions in which a party who induces another to break a contract is liable to the adversary party, his liability is still clearer if instead of inducing the breach, he does some wrongful act which makes performance impossible.1 A had a contract with a railroad corporation B to construct a line of railroad, and was engaged in performing the contract. X, a rival company, bribed the officers of B to transfer to X all the stock of B, or put it under the control of X, and thus caused the general manager of B to withdraw the engineers of B from the work, without whom it could not proceed, and to give notices which caused A's tools and supplies to be seized and his workmen to be dispersed. A sued X; and it was held, on demurrer to A's petition, that he had stated a cause of action.2 So A, a real estate broker, effected a contract for the sale of realty between B, the vendor, and X, the vendee, under a contract whereby A was to look to B for his commission. X refused to perform and made it impossible for B to perform the contract to sell the realty, and thus deprived A of his commission. It was held that A could maintain an action against X for the damages thus caused.3 In some jurisdictions, however, the right of the injured party to recover from the party outside the contract, who has made performance impossible by some wrongful act, is denied. Thus A had a contract to furnish B with electricity by means of B's wire, under a contract by which A was not to be liable in case of interruption of the current without A's fault. X cut the wire. It was held that B could not maintain an action against X for the damage caused by interruption of the current.4 It will be observed that this theory results in freeing X from all liability for the real injury done by his wrongful act; and in denying to B the right to recover from anyone - a result which tends to show some error in the process whereby it was reached. So where A had agreed to support B and X by its negligence disabled A, and made it practically impossible for him to perform, it was held that B had no cause of action against X.5 A, the owner of certain realty, leased it to B. X entered, and built a fence thereon, as a result of which B left, and did not pay any rent. It was held that in the absence of fraud, A had not right of action against X.6
1 Angle v. Ry., 151 U. S. 1.
2 "If the Omaha company had by its wrongful conduct simply induced the Portage company to break its contract with Angle, it would have been liable to him for the damages sustained thereby. A fortiori when it not only induces a breach of the contract by the Portage company, but also disables it from performance." Angle v. Ry.. 151 U. S. 1, 15.
3 Livermore v. Crane, 26 Wash-529; 57 L. R. A. 401 ; 67 Pac. 221.