Florida Business Torts Update: Skytruck Co. LLC v. Sikorsky Aircraft Corp., 12-10708, 2012 WL 6198101 (11th Cir. 2012)

In Skytruck Co., LLC, an aircraft distributor (“Skytruck”) brought an action for tortious interference and unjust enrichment against an aircraft manufacturer following the manufacturer’s direct interaction with aircraft procurement firm contracting with the Air Force.  The manufacturer moved for summary judgment, which motion was granted by the district court.

On appeal, it was held that both claims failed, and the district court’s decision was affirmed. 

As to the tortious interference claim, it was held that the defendants were legally entitled to choose to decline to permit Skytruck to market products on their behalf or otherwise represent them, and were legally entitled to choose their own representatives and sell to parties of their own choice.  The law of tortious interference recognizes that economic relations are entitled to freedom from unreasonable interference. 

As to the unjust enrichment claim, after reviewing the evidence, the appellate court found that Skytruck’s exclusive distributorship role had been terminated by the defendants, and subsequently, Skytruck had attempted to resurrect some role for itself through various communications, all of which had been flatly rejected by the defendants.  In fact, after the termination of the distributorship, Skytruck had ensued communications with Sierra Nevada, which was assisting the United States Air Force with procurement of aircraft.  Defendants had no knowledge of Skytruck’s efforts with Sierra Nevada.

It was subsequent to these rejections, that the Air Force contacted the defendants to arrange for a factory visit, and the sales were subsequently negotiated and consummated between the defendants and the Air Force. 

On appeal, the district court’s rejection of the unjust enrichment claim on the basis of unclean hands and on the basis of the “officious intermeddler” doctrine, was affirmed.

The “officious intermeddler” doctrine was adopted by the Florida Supreme Court in Tipper v. Great Lakes Chemical, Co., 281 So. 2d 10 (Fla.1973), as follows:  “A person who without mistake, coercion or request has unconditionally conferred a benefit upon another is not entitled to restitution, except where the benefit was conferred under circumstances making such action necessary for the protection of the interests of the other person or of third persons.”

The appellate court noted that the exception set forth in Tipper did not apply to the case before it as any efforts by Skytruck with respect to Sierra Nevada were undertaken at its own risk, and even if Skytruck had conferred a benefit upon the defendants, Florida law does not empower a party in Skytruck's shoes to force itself upon a party in defendants' shoes and place defendants in the position of either accepting Skytruck's intrusion or foregoing a profitable sale to a customer like Sierra Nevada and the Air Force.

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