In other jurisdictions liability in tort for inducing a breach of contract is held not to exist in contracts outside of contracts of employment if no wrongful act exists other than inducing such breach.1 A leased rooms in a hotel to B. X induced A to break his contract and eject B. It was held that B had no right of action against X.2 So A agreed to sell tobacco to B. X induced A to sell this tobacco to X, knowing of A's contract with B. It was held that B could not recover from X.3 So A owed an account to B, an undertaker. All the undertakers in the city had agreed to serve no one who owed a bill to any member of their organization. A needed the services of an undertaker and applied to B, who refused him. He then applied to the other members of the association, each of whom refused him. It was held that A had no right of action against B.4 A can not maintain an action against X for inducing B to break his contract to marry A, if X is not guilty of slander.5 A and B were engaged to be married. A's father, X, advised A to break the engagement and finally induced A to do so. It was held that B had no right of action against X for interference with contract. her only remedy being an action for slander if X had been guilty of that tort.6

13 National Phonograph Co. v. Edison-Bell Consolidated Phonograph Co. [1908], 1 Ch. 335.

14 National Phonograph Co. v. Edison-Bell Consolidated Phonograph Co. [1908], 1 Ch. 335.

1Boyson v. Thorn, 98 Cal. 578. 21 L. R. A. 233, 33 Pac. 492; Chambers v. Baldwin, 91 Ky. 121, 34 Am. St. Rep. 165, 11 L. R. A. 545, 15 S. W. 57: Homan v. Hall, 102 Neb. 70, L. R. A. 1918C. 1195, 165 N. W. 881; Swain v. Johnson. 151 N. Car. 93, 28 L. R. A. (N.S.) 615. 65 S. E. 619: Sleeper v. Baker, 22 N. D. 386, 39 L. R. A. (N.S.) 864, Ann. Cas. 1914B, 1189, 134 N. W. 716.

It is said that X is liable to B, outside of employment contracts, only if he is guilty of deception or coercion as against A. Swain v. Johnson, 151 N. Car. 93, 28 L. R. A. (N.S.) 615, 65 S. E. 619.

2Boyson v. Thorn, 98 Cal. 578, 21 L. R. A. 233, 33 Pac. 492.

3 Chambers v. Baldwin, 91 Ky. 121, 34 Am. St. Rep. 165. 11 L. R. A. 545, 15 S. W. 57.

4 Brewster v. Miller. 101 Ky. 368. 38 L. R. A. 505, 41 S. W. 301.

5 Homan v. Hall, 102 Neb. 70, L. R. A-1918C. 1195, 165 N. W. 881.

In some of the cases in which this doctrine has been announced, it may be doubted if the party whose liability in tort is sought to be enforced had committed any wrongful act. A had employed B for an indefinite term. X was A's foreman and had authority to discharge B. X quarreled with B, and instead of discharging B himself, X appealed to A, and notified him that if he did not discharge B, X would not work for A longer. A discharged B. It was held that B had no right of action against X.7 A had a contract with a railroad company, B, to haul sand and gravel which A was digging on land claimed by him, and was selling and shipping away. X claimed the same realty and notified B that he would hold him liable if he hauled such sand and gravel away. B broke his contract with A and refused to haul such sand and gravel. It was held that A had no right of action against X.8 In this case the court observed that the defendant corporation "had the undoubted legal right to protect its property interests in that manner." but at the same time the court further said that the doctrine of Lumley v. Gye was limited to interference between master and servant. A had given an option on certain realty to B. It was doubtful if B had any rights as against A, as he had not accepted the option in time; but A was ready to convey to B if B would pay the purchase price; and A had placed a deed with his attorney, Y. to deliver to B if B elected to take the land in a certain further period. B did not make such payment and X then bought such land from A. It was held that B had no right of action against X.9