Narrative Opinion Summary
This case involves a dispute between an employer, Eagle Systems, and a former employee, Diana Black, concerning breaches of duty of loyalty under the Restatement (Second) of Agency section 393. The district court found that Black violated her duty by soliciting Eagle's drivers and employees to join a competitor, E.T. Schmid, encouraging clients to switch their business, and performing dispatch services for E.T. Schmid while still employed by Eagle. In addition, E.T. Schmid Trucking was held liable for knowingly aiding Black's breach, pursuant to section 312 of the Restatement. The appellate court reviewed the district court’s factual findings under the 'clearly erroneous' standard and affirmed the decision, concluding that no further examination of other alleged errors was necessary. The court's memorandum is not intended for publication or citation, except as permitted by Ninth Circuit Rule 36-3, thereby limiting its precedential value.
Legal Issues Addressed
Breach of Duty of Loyalty under Restatement (Second) of Agencysubscribe to see similar legal issues
Application: The court found that the employee breached her duty of loyalty by soliciting drivers and employees, encouraging business to move to a competitor, and working for a competitor while still employed.
Reasoning: In the case of Eagle Systems v. Diana Black, the district court determined that Black breached her duty by: 1) soliciting Eagle's owner-operator drivers and employees to join E.T. Schmid; 2) encouraging intermodal shipping companies and consignees to switch to E.T. Schmid; and 3) dispatching for E.T. Schmid while still employed by Eagle.
Liability for Assisting Breach of Duty under Restatement (Second) of Agencysubscribe to see similar legal issues
Application: E.T. Schmid Trucking was found liable for knowingly assisting Black in breaching her duty of loyalty, thus violating section 312.
Reasoning: Furthermore, E.T. Schmid Trucking was found liable for knowingly aiding Black in her actions, as outlined in Restatement (Second) of Agency section 312, which holds individuals accountable for assisting an agent in violating their duty to the principal.
Standard of Review for Factual Findingssubscribe to see similar legal issues
Application: The court upheld the district court's findings as not clearly erroneous, affirming the lower court's decision.
Reasoning: These findings were upheld as not clearly erroneous.