Petrie, C.J.

The defendant, City of Redmond, appeals from a judgment awarding plaintiff, Jerry Houser, damages for interference with his employment as a City of Redmond police officer.

Early in 1972, Sergeant Jerry Houser of the Redmond City Police Department concealed a,tape recorder in his squad room locker and surreptitiously recorded the conversations of several fellow police officers. On April 26, 1972, Houser discovered that his locker had been broken into and his tape recorder rendered inoperable. He thereupon filed a written request for a formal police department investigation into the incident. Sergeant Sherman, as head of detec*744tives, was assigned to investigate with Detectives Crossland and Sheehan assisting.

On May 18, 1972, Sgt. Houser was dismissed from the Redmond police force for

Recording private conversations of fellow police officers without their knowledge or consent by means of an electronic device in direct violation of RCW 9.73.030[1]i on or about February 27, 1972, February 28, 1972, and on several previous occasions, within the Redmond Police Department Squad Room in the City Hall, Redmond, Washington.

Sergeant Houser sought review of his dismissal before the Civil Service Commission, and a hearing was conducted on June 13, 1972. He was represented by counsel at this open public hearing during which testimony, exhibits, and other evidence were submitted in support of, and in opposition to, the police action. Several police officers testified that they recognized their own voices on the tape which Houser had turned over to the investigating detectives and that the recordings were obtained without their knowledge or consent. In response to a question posed by Houser’s attorney, Sgt. Sherman indicated that a complete investigation into the break-in of Houser’s locker had been conducted but the identity of the culprit had not as yet been determined. On June 20, 1972, the Civil Service Commission issued a decision which upheld the discharge of Sgt. Houser. He then appealed that decision to King County Superior Court. The court affirmed the decision of the commission on December 28,1972. No further appeal was taken from that order.

On March 19, 1973, Houser discovered that the perpetrators of his locker break-in were, in fact, the very same *745individuals who had been assigned to investigate the. incident—Detectives Sherman, Crossland, and Sheehan. Based on this newly found evidence, Houser filed a motion to vacate the Superior Court judgment but withdrew the motion before formal action was taken upon it. He decided, instead, to pursue a different course of action and thus instituted the suit from whence this appeal follows.

The essence of plaintiff’s complaint was the allegation that employees of the defendant, City of Redmond, tortiously interfered with his employment resulting in his discharge from the City of Redmond police force. More specifically, plaintiff claimed that the interference consisted of perjury and suppression of relevant evidence by other city employees, depriving him of a fair hearing before the Civil Service Commission.

Trial to a jury resulted in a verdict for Houser in the amount of $30,000. Post-trial motions were denied, and judgment was entered on January 14,1975.

Although there are 23 assignments of error set forth in the City of Redmond’s brief, our decision to reverse and remand for dismissal is based on the resolution of the following single issue: Whether an employee may subject his ■employer to liability for tortiously interfering with their employment relationship? Because the answer to that question is “No,” plaintiff’s complaint fails to state a cause of action.

The elements of the tort of malicious interference with contractual relations are set forth in the Restatement ■of Torts § 766, at 49 (1939):

Except as stated in Section 698, [not relevant here] one who, without a privilege to do so, induces or otherwise purposely causes a third person not to

(a) perform a contract with another, or

(b) enter into or continue a business relation with another

is liable to the other for the harm caused thereby.

(Italics ours.) The tort has its origin in the decision of Lumley v. Gye, 118 Eng. Rep. 749 (1853). In that case a ■competitor induced opera star Johanna Wagner to breach *746her contract to perform for plaintiff. The court held that, as between the contracting parties, the contract itself provided a sufficient remedy. To compensate for the wrong done by the noncontracting party in inducing the breach of contract, however, the court held tort liability was in order. Hence, consistent with the reasoning behind the origin of this action, the law has developed that “[t]he defendant’s breach of his own contract with the plaintiff is of course not a basis for the tort.” W. Prosser, Law of Torts § 129, at 934 (4th ed. 1971).

Plaintiff contends, though, that Washington recognizes liability for tortious interference with the contract of two contracting parties, citing for authority several labor union cases. E.g., Minch v. Local 370, IUOE, 44 Wn.2d 15, 265 P.2d 286 (1953); Leo v. Local 612, IUOE, 26 Wn.2d 498, 174 P.2d 523, 168 A.L.R. 1440 (1946). These cases do not support plaintiff’s position; each involves a requisite third party, i.e., an employee’s relationship with his employer was interfered with by the third party union.

In any event, this issue has been specifically addressed in Hein v. Chrysler Corp., 45 Wn.2d 586, 277 P.2d 708 (1954) where at page 596 the court quotes approvingly from Canister Co. v. National Can Corp., 96 F. Supp. 273, 274 (D. Del. 1951):

an action for inducing a breach of contract will lie against a third party but a party to the contract itself can not be held responsible [in tort] for inducing himself to commit a breach of that contract or for conspiring to breach it.”

Therefore the City of Redmond is incapable of tortiously interfering with the employment relationship between it and its employee, Houser.

Plaintiff attempts to distinguish the case at bench, however, by invoking the rule that an employer is bound by the misconduct or the negligence of his employee when the employee is acting in furtherance of the legitimate interests of his employer. Greene v. St. Paul-Mercury Indem. Co., 51 Wn.2d 569, 320 P.2d 311 (1958). Thus, plaintiff ingeniously *747argues, the misconduct of “third party” city employees is imputed to the City of Redmond rendering it liable for a tort it could not otherwise commit. The plaintiff specifically alleges in his complaint that his discharge was the result of tortious misconduct performed by City of Redmond employees “in the course of their official duties.” It is precisely because of this allegation that plaintiff’s argument fails.

To be actionable, the interference must be both wrongful and unprivileged. See Calbom v. Knudtzon, 65 Wn.2d 157, 396 P.2d 148 (1964). Agents and employees are not subject to liability for inducing their principal’s or employer’s breach of contract if they act in their official capacity on behalf of their principal or employer. Their actions in this respect are privileged. See May v. Santa Fe Trail Transp. Co., 189 Kan. 419, 370 P.2d 390 (1962); Bliss v. Southern Pac. Co., 212 Ore. 634, 321 P.2d 324 (1958).

Thus, the claim that the City of Redmond is vicariously liable for its employees’ interference fails because that conduct, being privileged, is not actionable. Only if defendant’s employees had not acted within the scope of their official capacity could they have been liable for tortious interference, but then, of course, only in their personal capacity, because the doctrine of respondeat superior would not apply. Hein v. Chrysler Corp., supra at 599.

The judgment is reversed and the cause remanded with instructions to dismiss the action.

Reed, J., and Hale, J. Pro Tern., concur.

Petition for rehearing denied March 9, 1977.

Review granted by Supreme Court July 27,1977.

Wilkins, J.

We granted further appellate review (see United Truck Leasing Corp. v. Geltman, 26 Mass. App. Ct. 847 [1989]), to consider what elements a plaintiff must prove *812 in order to present a jury question (1) on a claim of intentional interference with a contract and (2) on a claim of intentional interference with a prospective contractual relation. The trial judge and the Appeals Court have disagreed on one crucial element of the tort of intentional interference with a contract. The trial judge directed a verdict for the defendants on that claim, and the Appeals Court has concluded that he should not have done so. Id. at 853-854. We granted the defendants’ application for further appellate review of this issue.

It is common ground that, in an action for intentional interference with a contract, the plaintiff must prove that (1) he had a contract with a third party, (2) the defendant knowingly induced the third party to break that contract, and (3) the plaintiff was harmed by the defendant’s actions. See id. at 852, and cases cited. The disputed point is whether the plaintiff must also prove something more, namely, that a defendant’s conduct was wrongful or improper in some way. The trial judge recognized that our cases have said that justification for one’s conduct is an affirmative defense to be proved by the defendant (see, e.g., Owen v. Williams, 322 Mass. 356, 360 [1948]), but he concluded, relying on principles set forth in the Restatement (Second) of Torts § 767 (1979), that, before the matter of justification need be faced, a plaintiff must prove that what the defendant intentionally did was “wrongful or improper in its means or its ends.”

The Appeals Court noted that the Restatement (Second) of Torts had moved away from the position taken in the Restatement of Torts § 766 (1939) which, in the Appeals Court’s view, more accurately stated the law of the Commonwealth. Id. at 852 & n.2. 2 That court also noted that *813 certain other States had adopted a requirement of proof of wrongful conduct beyond the intentional interference itself. Id. at 852 n.2. The Appeals Court was not considering whether a change or redefinition of the law of the Commonwealth was called for. It simply applied the Massachusetts law, as it perceived it, and ordered a new trial on the claim of intentional interference with a contract.

Our cases have been imprecise on the elements of the torts involved in this case. There is arguably support for the positions taken by both the trial judge and the Appeals Court. Before we undertake to redefine and, we hope, clarify the torts, we shall briefly outline the circumstances that gave rise to the claims in this case.

Geitman, an officer of the defendant corporation, counsels companies that lease trucks. He educates his customers about the truck leasing business so that they may obtain more favorable leases. He helps in soliciting and critiquing bids from lessors and sometimes negotiates leases. Geitman also attempts to obtain changes in existing leases that will be beneficial to his clients. The plaintiff (United) operates a large truck leasing company in the Commonwealth.

United’s claim for intentional interference with a contract is based on its claim that Geitman caused one of his customers (Universal Fixtures) to break its contract with United and to enter into a lease with Flexi-Van, the lessor with whom Universal Fixtures had had a lease prior to its lease with United. It is clear, on the plaintiffs evidence, that Geitman knew of the existing lease between United and Universal Fixtures and recognized the possibility that, if Universal Fixtures signed on with Flexi-Van, United might sue Universal Fixtures for breach of contract. There was evidence that United lost $60,000 because of Universal Fixtures’s repudiation of the contract.

United’s claim for intentional interference with prospective contractual relations concerns United’s inability to obtain a lease with Matthew’s Salad House (Matthew’s). United had been trying to arrange a lease with Matthew’s for about six *814 years. 3 Matthew’s retained Geltman to advise it concerning the lease of refrigerated trucks. Geltman did not invite United to bid on the Matthew’s account, although there were good reasons why United might have been invited to do so. When asked by a United representative why he had not invited United to bid, Geltman replied that other leasing companies gave him leads for new accounts but that United did not. After learning the amount of its competitor’s bid, United did bid on the Matthew’s account but was not awarded the account. 4 The trial judge directed a verdict for the defendants on this claim. The Appeals Court agreed with his ruling. United Truck Leasing Corp. v. Geltman, supra at 855-856. United has sought, and we have granted as to United, limited further appellate review of the order directing a verdict against United on its claim for interference with its prospective contractual relations with Matthew’s.

We start with the observation that malice, in the sense of ill will, has not been a true element of the torts of intentional interference either with a contract or with a prospective contractual relation. See Pino v. Trans-Atl. Marine, Inc., 358 Mass. 498, 504 (1970); Restatement of Torts § 766 comment m, special note (1939). Some of our cases have used the word but, in the same breath, have eliminated any requirement of independent proof of malice. See Keegan v. O’Donnell, 310 Mass. 346, 350 (1941) (“intentional interference with the plaintiffs business, in the absence of any legal justification, was malicious in law and entitled the plaintiff to damages”); Anderson v. Moskovitz, 260 Mass. 523, 526 *815 (1927) (“Malice is proved if it appears that the defendant with knowledge of the contract intentionally and without justification induced one of the contracting parties to break it”); Berry v. Donovan, 188 Mass. 353, 356 (1905) (“[a]n intentional interference . . . without lawful justification, is malicious in law”). This formulation of the tort, intentional interference without privilege to do so, is generally consistent with the rule stated in the first Restatement, 5 and, as we have said, guided the Appeals Court in reaching its decision.

More recently, we have expressed the view that a plaintiff must prove, among other things, “the defendant’s intentional and malicious interference with” a business relationship or contemplated contract of economic benefit. See ELM Medical Laboratory, Inc. v. RKO Gen., Inc., 403 Mass. 779, 787 (1989). The court thus required proof not only of intentional conduct but also of malicious conduct. Although we now abandon the word malicious in the description of any element of these torts, we affirm our recent statement that something more than intentional interference is required. In Comey v. Hill, 387 Mass. 11, 19 (1982), we described the tort as requiring proof of both intentional and malicious interference. We characterized the element of wrongful conduct, supporting submission of the case to the jury, as conduct by the defendant intended to discriminate against the plaintiff because of his age. Id. at 19-20. 6

*816 In this opinion, we adopt the word “improperly” in place of the word “maliciously.” In doing so we agree that more than intentional interference must be established. “Improperly” is the word used in the Restatement (Second) of Torts § 766 (1979) 7 (“intentionally and improperly interferes”). It is the concept the trial judge relied on in directing verdicts in this case. We accept it, as does the Restatement (Second) of Torts, as an element both in the proof of intentional interference with performance of a contract (§ 766) and in the proof of intentional interference with a prospective contractual relationship (§ 766B).

In deciding what conduct is improper, we accept the standard expressed in the out-of-State cases cited in the Appeals Court opinion. See 26 Mass. App. Ct. at 852 n.2, citing Top Serv. Body Shop, Inc. v. Allstate Ins. Co., 283 Or. 201, 209-210 (1978) (“In summary, [a claim of tort liability for intentional interference with contractual or other economic reíatians] is made out when interference resulting in injury to another is wrongful by some measure beyond the fact of interference itself. Defendant’s liability may arise from improper motives or from the use of improper means. ... No question of privilege arises unless the interference would be wrongful but for the privilege; it becomes an issue only if the acts charged would be tortious on the part of an unprivileged defendant”); 8 Leigh Furniture & Carpet Co. v. Isom, 657 P.2d 293, 304 (Utah 1982) (“improper purpose or by im *817 proper means”); 9 Blake v. Levy, 191 Conn. 257, 262 (1983) (“the better reasoned approach requires the plaintiff to plead and prove at least some improper motive or improper means”). In Comey v. Hill, supra, we applied this standard by recognizing liability where the defendant’s intentional interference with the plaintiff’s employment contract was based on unfair age discrimination, an improper motive.

The plaintiff has not argued that, if the trial judge’s requirement of proof of improper interference is applied, the evidence presents a jury question. The evidence does not warrant a finding that Geltman violated a statute or a rule of common law. There is no evidence that he used threats, misrepresented any facts, defamed anyone, or used any other improper means in relation to either the existing contract or the prospective one. 10 His apparent motives were to benefit his customers and himself financially. There is not enough evidence to warrant a finding that his real motive in these matters was to hurt United.

The judge properly allowed the motion for a directed verdict on the claims we have considered in this appeal.

Judgment of the Superior Court affirmed.

RICHARDSON, P. J.

Plaintiffs brought this action for intentional interference with business relations, contending that defendant bank wrongfully repossessed plaintiffs’ equipment and thereby prevented them, as joint venturers, from performing a road maintenance project for the United States Army. The tried court directed a verdict for defendant. Plaintiffs appeal, and we reverse.

John Hickman is the principal of plaintiff Hickman Construction, Inc. (Hickman). Ed Funderburk was the principal of plaintiff Funderburk Construction, Inc. (Funderburk). The two corporations formed the joint venture to bid on the Army contract and were notified on April 15, 1988, that theirs was the lowest qualified bid. Defendant had a security interest in Funderburk’s equipment and machinery as collateral for an equipment loan. Defendant also stood in various other creditor relationships with Funderburk, and it maintains that the transactions were “cross-collateralized. Funderburk’s payment record on the debts was spotty.

On April 17 or 18, Ed Funderburk tendered a payment on the equipment loan to defendant. According to plaintiffs’ evidence, defendant failed to apply the payment to interest first, with the result that it mistakenly concluded that there was a delinquency. On April 27, Ed Funderburk died. The next day, defendant contacted Ed’s daughter, Sandra Corno, who was an officer of Funderburk, to inform her of the status of the loans and that defendant intended to move the secured equipment to a new location for safety purposes. Corno and defendant’s officers met on April 29 and again on May 3. At the earlier meeting, Corno surrendered the keys to the equipment “under protest.” Defendant formally repossessed the equipment on May 4. When the Army learned of the repossession, it awarded the contract to another bidder;

Before Corno’s May 3 meeting with defendant’s officers, the officers had understood John Hickman to be a “partner” of Ed Funderburk. At that meeting, however, Corno made a concerted effort to downplay his role. She referred to him as an “employee” and noted that she would “handle all the money.” She explained at trial that the reason *530was her concern that, because she is a woman, defendant’s personnel would deal with him rather than her if they thought that he was a manager of the project.

The trial court directed the verdict on the grounds that the jury could not reasonably find that defendant was aware that Hickman was a joint venturer or principal rather than an employee of Funderburk and that there was no evidence that defendant acted with improper motives or means rather than for legitimate business reasons. Plaintiffs assign error to both facets of the ruling.

The parties agree with the trial court’s approach that plaintiffs were required to prove that defendant was aware of the nature of the relationship between them. In Willamette Quarries v. Wodtli, 308 Or 406, 413, 781 P2d 1196 (1989), the court said that, “[wjithout evidence establishing knowledge of a contractual [or economic] relationship, intentional interference with that contractual relationship cannot be proved. ’ ’ Here, the relationship that was allegedly disrupted was between plaintiffs and the Army, not the one between the two plaintiffs themselves. Arguably, however, Hickman’s status as a principal had to be proved in order to show that both plaintiffs, rather than Funderburk alone, had a business relationship with the Army. In any event, we will assume the parties’ premise.

The parties disagree about whether April 29 or May 4, the date of the “formal” repossession, was the day that the alleged interference occurred. Defendant maintains that the later date is the relevant one, as a matter of law; plaintiffs argue that which date is relevant is a question of fact. The significance of the dispute is that, according to defendant, its earlier awareness that Ed Funderburk and John Hickman were “partners” dissipated on May 3, when Corno suggested that John Hickman was a mere employee. We disagree. It remained a question of fact whether defendant’s earlier understanding continued or was displaced completely by Corno’s statements at the meeting. Moreover, there was evidence that, after the May 3 meeting, John Hickman was referred to as a partner in an interoffice memorandum of defendant’s, and that defendant consulted financial institutions about John Hickman after that date. The jury could find from the evidence that defendant was aware of the nature of *531John Hickman’s role and of plaintiffs’ relationship, and so the first ground for the directed verdict was error.

Plaintiffs’ next argue that “wrongful seizure of collateral constitutes improper means” and that the court therefore also erred by granting the directed verdict for the second reason. In its brief, defendant accepts three of plaintiffs’ critical premises:

1. ‘ ‘Defendant concedes that the improper seizure of collateral could rise to the level of improper means, since it would violate both statute and a rule of common law.”

2. “Defendant * * * concedes that privilege is not at issue when a showing is made that a defendant acted with improper means.”

3. “Plaintiffs’ argument that the defendant acted with improper means is predicated entirely upon the theory that the equipment loan was not past due at the time of the repossession. Because the court granted the motion for directed verdict at the close of plaintiffs’ case, there is no conclusive evidence in the record with respect to this issue.”1

Taken together, we understand the concessions to mean that defendant does not contend that, as a matter of law, wrongful repossession could not give rise to the tort of intentional interference.

Defendant contends, however:

“What [plaintiffs’] argument ignores, however, are the other provisions in the security agreements which cross-collateralize the loans and give the defendant the right to repossess if it deems itself insecure. Regardless of the status of the equipment loan, the line of credit was in default, and had been for some time. Under the cross-collateralization provisions of the security agreements, this in and of itself gave the defendant the right to repossess. In addition, the equipment loan security agreement gave the defendant the right to repossess if it reasonably deemed itself insecure.

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“The defendant in this case can be liable for intentional interference with a contract only if it acted with ‘improper means’ when repossessing the collateral. In this case, proving improper means would require plaintiffs to put on *532evidence negating any justifiable claim to repossess that defendant would have under the Uniform Commercial Code. No reasonable juror could conclude that plaintiffs succeeded in doing this, regardless of whether the equipment loan was in default.”

We disagree. Plaintiffs offered evidence not only that the repossession was based on the supposed interest arrearage under the equipment loan, but also that defendant could not or would not have seized the equipment under any other provision of the security instruments. More fundamentally, a plaintiff s burden in an intentional interference action is not to negate every possible proper basis for the defendant’s action. All that is necessary to prove improper means or motives is evidence of an improper means or motive that the jury can believe was the reason for the action. See Harm v. Central Life Assurance Co., 107 Or App 708, 714, 813 P2d 1103 (1991). Plaintiffs met that burden here, and the directed verdict was error.

Reversed and remanded.

Justice DURHAM,

opinion of the Court:

INTRODUCTION

1 1 This appeal concerns claims for tortious interference with economic relations by Joseph and Lindsey Eldridge against David Johndrow. Johndrow moved for summary judgment, and the district court partially granted his motion, concluding there was no evidence that he had interfered with the Eldridges' economic relations through an improper means. But the court denied sum *555 mary judgment for the Eldridges' claims based on the allegation that Johndrow had acted with an improper purpose.

{2 According to our decision in Leigh Furniture & Carpet Co. v. Isom, "improper purpose ... will support a cause of action for intentional interference with prospective economic relations even where the defendant's means were proper." 657 P.2d 293, 307 (Utah 1982). Leigh Furniture recognized, however, that this doctrine posed risks. There are "[plroblems inherent in proving motivation or purpose," and if juries were allowed to find improper purposes too easily, it would result in tort liability for much legitimate "competitive commercial activity." Id. We therefore sought to cireumseribe the doe-trine by allowing improper-purpose lability only where "the improper purpose predominate[s]" and by counseling that it would usually be "prudent" not to apply the doctrine to "commercial conduct." Id.

T3 Unfortunately, as the few subsequent cases allowing improper-purpose liability demonstrate, our efforts to cireumseribe the doctrine have failed. Infro ¶¶ 46-50. Because of this failure, little law exists to guide juries' improper-purpose findings or to inform private parties of their legal rights and obligations. Infra ¶¶ 51-54. Consequently, if improper-purpose claims became commonplace, their unpredictable nature would deter much socially beneficial speech and conduct.

T4 We could attempt to ameliorate this lawlessness by further refining the improper-purpose doctrine; for example, we could establish safe harbors like the Restatement's rule that the communication of truthful information never constitutes tortious interference. See RestatemEnt (SEconp) or Torts § 772(a) (1979). But we are persuaded that the doctrine's flaws warrant not repair but rejection. We therefore hold that no tortious interference claim can succeed without evidence of improper means.

BACKGROUND 1

T5 Appellees Joseph and Lindsey El-dridge are the owners and operators of Harrison Companies, LLC, and Harrison Companies Property Management, LLC. Through these limited liability companies, the Eldridges manage residential property and provide various other services for wealthy homeowners in Summit County. Because providing these services means taking responsibility for clients' homes, the El-dridges' success depends a great deal on their reputation.

T 6 Appellant David Johndrow is a former friend and client of the Eldridges who used to recommend their services to his friends and other associates in the area. But the friendship lasted only a year. Lindsey El-dridge accused Mr. Johndrow of attacking her at a restaurant, and Mr. Johndrow accused the Eldridges of spreading false rumors and stealing his mobile phone. The once amicable relationship gave way to threats of legal action.

17 The action Johndrow actually took, however, did not involve a lawsuit. Instead, he "turned [the matter] over" to an "investigative team," which discovered various embarrassing facts about the Eldridges: liens, a foreclosure, an old felony conviction, and unflattering news reports from before they moved to Utah. Mr. Johndrow threatened that if the Eldridges refused to retract their accusations and compensate him for the allegedly stolen phone, he would have to protect his "credibility" by revealing what he had found to the people to whom he had recommended the Eldridges. When the El-dridges did not accede to his demands, he emailed embarrassing information to "at least nine" of the Eldridges' institutional clients and communicated it verbally to a number of their individual clients.

18 The Eldridges sued, asserting several theories of liability: tortious interference with economic relations, tortious interference with prospective economic relations, defamation, false light, and intentional infliction of emotional distress. The tortious interference theories each rested on two separate allegations: first, that by defaming the Eldridges, *556 Mr. Johndrow had interfered with their economic relations through an improper means; and second, that because Mr. Johndrow's only goal was to hurt the Eldridges' business, he had interfered with their economic relations in pursuit of an improper purpose. 2

T9 After preliminary discovery, Mr. John-drow moved for summary judgment on the tortious interference claims, the defamation claim, and the false light claim. The district court concluded that the information John-drow had disseminated was "at least substantially true" and "not susceptible to a defamatory interpretation." It therefore granted summary judgment on the defamation and false light claims. Further, because the "improper means" basis for tortious interference liability depended on Johndrow's alleged defamation of the Eldridges, the court granted summary judgment on the tortious interference claims insofar as they were based on improper means.

110 However, the district court denied summary judgment on the tortious interference claims insofar as they were based on allegations of improper purpose. Mr. John-drow had argued that the court should follow the Restatement and hold that the communication of "truthful information," regardless of purpose, cannot constitute tortious interference. REstaATEMENT (SEconp) or Torts § 772(a) (1979). But the court relied on our decision in Pratt v. Prodata, Inc., which explicitly rejected the Restatement's truth defense in the context of improper-purpose claims. 885 P.2d 786, 790 (Utah 1994). Correctly concluding that the reconsideration of Pratt was a matter for a higher tribunal, the court denied summary judgment with respect to the Eldridges' improper-purpose claims.

111 Mr. Johndrow filed an interlocutory appeal, and we reverse.

STANDARD OF REVIEW

112 Denials of summary judgment are reviewed for correctness. Glenn v. Reese, 2009 UT 80, ¶ 6, 225 P.3d 185.

ANALYSIS

{13 The Eldridges' remaining tortious interference claims depend on the allegation that Mr. Johndrow interfered with their economic relations for an improper purpose. This improper-purpose doctrine was adopted in Leigh Furniture & Carpet Co. v. Isom: "[IJn order to recover damages [for tortious interference], the plaintiff must prove (1) that the defendant intentionally interfered with the plaintiff's existing or potential economic relations, (2) for an improper purpose or by improper means, (8) causing injury to the plaintiff." 657 P.2d 293, 304 (1982) (emphasis added). The Leigh Furniture court made clear that "improper purpose (or motive, intent, or objective) will support a cause of action for intentional interference with prospective economic relations even where the defendant's means were proper." Id. at 307.

14 For reasons we articulate below, see infra TN we hereby reject the improper-purpose rule. Contrary to Leigh Furniture, we hold that a claim for tortious interference may only succeed where the defendant has employed an improper means.

15 Before we explain our reasons for rejecting improper purpose liability, we must deal with two obstacles to our rejection of the doctrine. First, we conclude that although the reconsideration of improper purpose liability was not Mr. Johndrow's chief argument on appeal, it is nevertheless properly presented for our consideration. See infro TJ 16-19. Second, we conclude that stare decisis does not prevent us from abandoning the improper purpose doctrine. See infra ¶¶ 20-41.

I. RECONSIDERATION OF THE IMPROPER-PURPOSE DOCTRINE IS PROPERLY BEFORE THE COURT

116 In Pratt v. Prodata, Inc., we declined to reconsider our support for improper-purpose liability because the parties had not asked us to do so and the question *557 was therefore not properly presented. 885 P.2d 786, 789 n. 8 (Utah 1994) (opinion of Zimmerman, C.J.). The same obstacle does not exist in this case.

117 Admittedly, Johndrow's first brief did not focus on reconsideration of the improper-purpose doctrine, instead arguing that we should follow the Restatement and declare that truth is an absolute defense to tortious interference liability. See REstaTEMENT (SEconp) or Torts § 772(a) (1979). It did, however, explain at some length "the difficulties associated with the improper purpose prong" and acknowledged that these difficulties could lead the court to "undertake a complete reconsideration" of it. In particular, it pointed out how "problematic" it is to "permit{ ] liability for otherwise legal and permissible conduct if the defendant can be said to have acted with "IIl will towards the plaintiff." Further, it argued that a growing number of states have limited or rejected claims based solely on improper purpose.

{18 The Eldridges' brief seized on this discussion, accusing Johndrow of demanding the abandonment of improper-purpose liability and offering a full-throated defense of the doctrine: "Essentially, Johndrow asks this Court to reverse itself and impose a black-letter and inflexible standard that would protect extremely malicious conduct.... The improper purpose prong as currently utilized and applied by Utah courts strikes a fair and appropriate balance between the interests of the various parties...." Johndrow's reply brief disclaimed that reconsideration of improper-purpose liability was necessary to its case, but it repeated its arguments against the doctrine and expressly invited the court to reconsider it.

T19 The reconsideration of improper-purpose liability has thus been explicitly raised by the parties and adequately argued in their briefs. We may therefore reach this issue.

II. STARE DECISIS DOES NOT PRECLUDE RECONSIDERATION OF THE IMPROPER-PURPOSE DOCTRINE

120 The Eldridges urge that "[tlhe district court's decision should be affirmed because it is mandated by the doctrine of stare decisis." Although the Eldridges are correct that stare decisis required the district court to deny summary judgment, 3 the doctrine does not prevent this court from reconsidering its precedents when it is appropriate to do so.

21 Stare decisis "is a cornerstone of Anglo-American jurisprudence" because it "is crucial to the predictability of the law and the fairness of adjudication." State v. Thurman, 846 P.2d 1256, 1269 (Utah 1993). Because stare decisis is so important to the predictability and fairness of a common law system, we do not overrule our precedents "lightly." State v. Hansen, 734 P.2d 421, 427 (Utah 1986) (plurality opinion).

122 However, our presumption against overruling precedent is not equally strong in all cases. See State v. Menzies, 889 P.2d 393, 399 (Utah 1994) ("[Stare decisis] is neither mechanical nor rigid as it relates to courts of last resort."); 20 Am.Jur.2d Courts § 131 (2005) ("[The principle [that a court should not overrule its own precedents] is not a binding legal rule to be blindly followed. ..."). Our decisions have identified two broad factors that distinguish between weighty precedents and less weighty ones: (1) the persuasiveness of the authority and reasoning on which the precedent was originally based, and (2) how firmly the precedent has become established in the law since it was handed down. The second factor encompasses a variety of considerations, including the age of the precedent, how well it has worked in practice, its consistency with other legal principles, and the extent to which people's reliance on the precedent would create injustice or hardship if it were overturned.

123 As we discuss below, none of the factors that give stare decisis special weight are present here.

A. The Improper-Purpose Doctrine Rests on Weak Authority and Reasoning

124 The first factor in determining how much deference a precedent should be *558 afforded is the persuasiveness of the authority and reasoning on which the precedent is based. See Laney v. Fairview City, 2002 UT 79, ¶ 46, 57 P.3d 1007 (plurality opinion) ("[Thlhe precedent rejected in Menzies was established 'with little analysis and without reference to authority'" (quoting Menzies, 889 P.2d at 399)); accord Montejo v. Louisiana, 556 U.S. 778, 792-93, 129 S.Ct. 2079, 173 L.Ed.2d 955 (2009) relevant factors in deciding whether to adhere to the principle of stare decisis include ... whether the decision was well reasoned.").

125 Here we note first that our cases supporting improper-purpose liability are themselves weak authorities on this issue. We first endorsed the improper-purpose doctrine in Leigh Furniture & Carpet Co. v. Isom, but the decision in that case did not actually rely on it. 657 P.2d 293, 308 (Utah 1982) ("[TJhe evidence in this case would not support a jury finding [of improper purpose]."). Because Leigh Furniture was decided on other grounds, its endorsement of improper-purpose liability was not, in the strictest sense, part of the case's holding. Its precedential weight is therefore limited. 4 See 20 Am.Jur.2d Courts § 134 (2014) ("[A] case is not authority for any point not necessary to be passed on to decide the case...."); Arthur L. Goodhart, Determining the Ratio Decidendi of a Case, 40 Yale L.J. 161, 161 (1930) ("In order that an opinion may have the weight of a precedent ... it must be an opinion the formation of which is necessary for the decision of a particular case. ...") 5

126 The only decision in which we have allowed liability based solely on an improper purpose is Pratt v. Prodata, Inc., which upheld a jury verdict based on improper purpose where the jury had found no improper means. 885 P.2d 786, 788-89 (Utah 1994). Pratt, however, is also a weak precedent because it merely assumed that Leigh Furniture's improper-purpose prong was good law, without hearing argument on that issue. Cf. 20 Am.Jur2D Courts § 134 (2014) ("For a case to be stare decisis on a particular point of law, that issue must have been raised in the action decided by the court.... [A] case is not binding precedent on a point of law where the holding is only ... assumed in the decision but is not announced." (emphasis added) (footnotes omitted)).

127 Further, only two of the four justices who decided Pratt actually endorsed improper-purpose liability. Pratt, 885 P.2d at 790-91 (Stewart, A.C.J., concurring). The other two expressed "grave doubts about the future vitality of Leigh's improper-purpose prong," but they declined to consider the issue because it was not properly "before the court." Id. at 789 n. 3 (opinion of Zimmerman, C.J.). That this court split evenly on improper-purpose liability twenty years ago, in a case where the issue had been neither raised nor argued by the parties, does not preclude us from reconsidering it today.

28 When we turn from the precedential status of Leigh Furniture and Pratt to the reasoning and authority on which they were based, we see nothing in either case that would make us hesitate to overrule them. To begin with, Pratt's application of improper-purpose liability was based entirely on Leigh Furniture, without any discussion of other authority. See id. at 788. As for its reasoning, two of the Pratt justices endorsed improper-purpose liability because it allowed courts to reach desirable results where "[iJn-fliction of gratuitous harm" might otherwise not be remedied. Id. at 791 (Stewart, A.C.J., concurring in the result). The other two worried about the doctrine allowing "wholly *559 legitimate" conduct to be declared tortious by "a jury's unguided exercise of its moral judgment." Id. at 789 n. 3 (opinion of Zimmerman, C.J.). Because reconsideration of the doctrine was not before the court, neither opinion did the hard work of weighing all the arguments and reaching a reasoned conclusion.

129 Leigh Furniture's endorsement of improper-purpose liability rested on more authority, but less reasoning. Leigh adopted the improper-purpose prong by adopting Oregon's definition of tortious interference. 657 P.2d at 304. Its argument for adopting Oregon's definition was simple and persuasive: the first Restatement put too little burden on plaintiffs making their case, the second Restatement put too much, and Oregon's "middle ground" was the best option available. Id.

T 30 But as sound as this reasoning was, it did not explain why improper purpose, in the absence of improper action, should constitute independent grounds for liability. On this crucial point, Leigh Furniture was silent. It warned against overuse of the improper-purpose prong. Id. at 307 ("[Xlt [is] prudent for commercial conduct to be regulated for the most part by the improper means alternative. ..."). It explained why the improper-purpose prong was problematic. Id. (acknowledging "[pJroblems inherent in proving motivation or purpose"). But nowhere did it explain why the improper-purpose prong was necessary at all.

131 Its inclusion of improper purpose in its reasoning therefore rested entirely on persuasive authority. See id. at 807-08 (citing a treatise and a handful of cases from other jurisdictions). Yet its appeal to authority on this issue was also weak because, as it acknowledged, there was "no generally acknowledged or satisfactory majority position" on the elements of tortious interference. Id. at 308-04. Rather, tortious interference law nationwide was "still in a formative stage." Id. at 304.

1 32 We do not wish to overstate the matter. Leigh Furniture is the seminal case of Utah's tortious interference law, and 'we would follow even its dicta if we had no good reason to do otherwise. However, on the narrow issue of improper-purpose liability, its authority is weak and its reasoning is nearly nonexistent. It does nothing to quell our concerns about the improper-purpose doctrine.

B. The Improper-Purpose Doctrine Is Not Firmly Established in Utah Law

T 33 Although our precedents adopting the improper-purpose prong are weak and unpersuasive, we would still hesitate to overrule them if the doctrine had become firmly established in Utah law. But examination of the cases applying Leigh Furniture demonstrates that it has not.

1, Age and Public Reliance

134 In determining how firmly a precedent has established itself in Utah law, we look to a variety of considerations. Supra ¶ 22. First, we look to the age of the precedent, since newer precedents are likely to be less firmly established. See Laney, 2002 UT 79, ¶ 46, 57 P.3d 1007 (plurality opinion). The doctrine at issue here was adopted thirty-two years ago in Leigh Furniture, without any significant precursors in Utah law. See Leigh Furniture, 657 P.2d at 304. While thirty-two years is more than enough time for a precedent to become firmly established if it is regularly used and relied on, we note that unlike the precedent we upheld in Laney, improper-purpose liability is not based on a legal principle established in "the earliest days of statehood." Laney, 2002 UT 79, ¶ 46, 57 P.3d 1007 (plurality opinion).

135 Second, we consider the extent to which people's reliance on the precedent would create injustice or hardship if it were overturned. As we recently stated in Cope v. Utah Valley State College,

[We consider whether overturning a pree-edent would undermine the public's substantial reliance upon an established legal principle.... [PlJeople should know what their legal rights are as defined by judicial precedent, and having conducted their affairs in reliance on such rights, ought not to have them swept away by judicial fiat.

*560 2014 UT 53, ¶ 19, 342 P.3d 243 (internal quotation marks omitted); accord 20 Am. Jur. 2D Courts § 182 (2014) ("[EQven if the earlier precedent was wrongfully decided, the court will not overrule the precedent where ... it has remained standing for a significant period and many have relied on it...." (emphasis added)).

136 When a doctrine has not been necessary to the outcome of many cases, it is unlikely that the public has relied on it in any substantial way. Cf. Cope, 2014 UT 53, ¶ 26, 342 P.3d 243 ("[When a case] has not become a well-entrenched or frequently applied precedent, the public's reliance upon [the case] is not as strong."). That is certainly the case here.

"137 This court, the court of appeals, and Utah's federal courts have quoted Leigh Furniture's "improper purpose" language in dozens of tortious interferences cases, but they have found evidence of improper purpose only three times. The first time was in Pratt, in which half the Court might have rejected the doctrine entirely if a party had asked it to do so. 885 P.2d at 789 n. 3. The second time was ProMax Development Corp. v. Mattson, in which the court of appeals affirmed a trial court's finding of improper purpose in circumstances similar to Pratt. ProMax Dev. Corp. v. Mattson, 943 P.2d 247, 254-55 (Utah Ct.App.1997). And the third time occurred in 2008, when the federal district court of Utah concluded that there was enough evidence of improper purpose for the issue to go to a jury. Peterson v. Luna Bronze, L.C., No. 2:07CV00054DS, 2008 WL 4180021, at *2 (D.Utah Aug. 14, 2008).

138 Far more common are the cases in which courts have rejected allegations of improper purpose. We have analyzed and rejected improper-purpose claims five times, 6 the court of appeals has done so once, 7 and the District of Utah has done so more than half a dozen times. 8 Often the improper-purpose doctrine has not been applied at all, either because parties have declined to raise the issue or because courts have chosen not to consider it. 9 Given the difficulty of winning claims under the fimproper-purpose doe-trine, it would have been foolhardy for people to rely on it in their private dealings.

189 The improper-purpose doctrine's vagueness further supports this conclusion. In order to rely on their rights under the improper-purpose doctrine, the Eldridges would have needed to know what those rights were. But as we explain below, knowing one's rights under the improper-purpose doe-trine is impossible because the doctrine is so poorly defined. See infra ¶¶ 46-54.

2. Other Factors Determining Whether a Precedent is Firmly Established

140 We use two more considerations to determine whether a precedent has be *561 come firmly established. First, we ask how well it has worked in practice. Laney, 2002 UT 79, ¶ 46, 57 P.3d 1007 (plurality opinion) (citing Menzies, 889 P.2d at 400); see also People v. Hernandez, 231 Ill.2d 134, 324 Ill.Dec. 511, 896 N.E.2d 297, 304 (2008) ("Good cause to depart from stare decisis also exists when governing decisions are unworkable...."). Second, we ask whether the precedent has become inconsistent with other principles of law. Cf. 20 Am. Jur. 2D Courts § 182 (2005) ("Another formulation of the grounds for deviation from precedent states that the court must consider ... whether the principles of law have developed to such an extent as to leave the old rule no more than a remnant of abandoned doctrine. ...").

{41 These considerations will be addressed in Part III, during our discussion of the merits of the improper-purpose prong. Neither of them, however, will alter the conclusion we reach based on the considerations above. Far from being firmly established, our improper-purpose doctrine has had little influence on litigation in this state.

III. THE IMPROPER-PURPOSE DOCTRINE SHOULD BE ABANDONED

11 42 If we were convinced that the improper-purpose doctrine served important public purposes, we would uphold it despite its weak basis in precedent. But our conviction is the opposite: improper purpose, in the absence of any improper means, should not be a basis for tortious interference Hability.

1 43 As our decisions have recognized, determining the predominant purpose behind a defendant's actions raises significant eviden-tiary problems. Because this inquiry is necessarily fact-intensive, appellate review has been limited, and little case law has developed to guide courts' and juries' work. The improper-purpose doctrine thus requires trial courts and juries to make decisions that are effectively without guidance.

144 This vagueness does more than lead to unpredictable verdiets. It also fails to give parties adequate notice of their rights and duties. If improper-purpose liability became commonplace, it would have a chilling effect on legitimate, socially beneficial competitive practices, Worse, it would chill speech, discouraging the free spread of information and opinion.

' 45 For these reasons, among others, other states have increasingly limited or rejected improper-purpose liability. In addition to supporting our arguments against improper-purpose liability, this trend further weakens the authority on which Leigh Furniture was based. With both contemporary authority and our own reasoning opposed to improper-purpose liability, we conclude that it should be rejected.

A. The Improper-Purpose Doctrine Provides Too Little Guidance for Courts and Juries

$46 Anger and even malice are commonplace human emotions, and it would be neither possible nor desirable to treat every angry or malicious action as a tort. Even a tort allowing liability whenever a defendant maliciously interfered with a plaintiff's economic relations would be unwise. As Leigh Furniture recognized, such a tort would interfere with "much competitive commercial activity, such as a businessman's efforts to forestall a competitor in order to further his own long-range economic interests." Leigh Furniture & Carpet Co. v. Isom, 657 P.2d 293, 307 (Utah 1982).

147 Leigh Furniture sought to foreclose this possibility by requiring plaintiffs to show not merely that an improper purpose was present, but that it predominated over legitimate motivations. Id. ("[The improper-purpose doctrine] takes the long view of the defendant's conduct, allowing objectionable short-run purposes to be eclipsed by legitimate long-range economic motivation."). Yet even so, it recognized that there were "[plroblems inherent in proving motivation or purpose" and cautioned against overuse of the improper-purpose prong. Id.

48 In Prott v. Prodata, Inc., Chief Justice Zimmerman argued that Leigh Furniture's efforts to limit the improper-purpose prong were inadequate. 885 P.2d 786, 789 n. 3 (Utah 1994) (opinion of Zimmerman, C.J.). Under Leigh Furniture's predominant-purpose standard, "all relevant considerations *562 are issues of fact," and "improper-purpose findings" are therefore "insulate[d] ... from meaningful appellate review." Id. Consequently, onee a plaintiff presents evidence of an improper purpose, no legal standard exists to guide fact-finders' determination of whether that purpose or the defendant's legitimate purposes predominated. Juries are required to look into the defendant's soul and discern which of her mixed motives was the real cause of her action-a question she herself, at the time she acted, may not have been able to answer with any certainty.

T49 The three Utah cases that have allowed improper-purpose claims demonstrate the perceptiveness of Chief Justice Zimmerman's critique. 10 In each case, the question of improper purpose reached the court in a procedural posture that permitted only minimal scrutiny. 11 In each case, there was clearly evidence to support a finding of a legitimate purpose. 12 And yet in each case, the court concluded that weighing the evi-denee of a proper purpose agairist the evidence of an improper purpose was a task for the finder of fact. 13

150 Were the approach of these cases followed in large numbers of cases, Leigh Furniture's efforts to limit the scope of the improper-purpose doctrine would be futile; any significant evidence of improper purpose would allow juries to find even the most commonplace commercial conduct tortious, no matter how much evidence could be presented of legitimate motivations. 14 The outcome of improper-purpose claims would thus depend more on jurors' personal sympathies for one party or the other than on any generally applied legal rule.

B. The Improper-Purpose Doctrine Gives Parties Inadequate Notice of Their Rights and Duties

151 Because improper-purpose findings are so dependent on fact-finders' personal sympathies, and so insulated from appellate review, the outcome of an improper-purpose suit becomes unpredictable as soon as any evidence of improper purpose is introduced. *563 This is a problem not merely because it may lead to unjust outcomes in individual cases, but because it makes it impossible for private parties to understand their rights and duties under tortious interference law.

T 52 Under the improper-purpose prong as it has developed, a business owner could be sued for undercutting his competitor's prices if he held a grudge against her. An investor in a Ponzi scheme might be sued for exposing the scheme if she did so with enough malice towards her swindlers. And a customer leaving angry reviews online might receive a response to her complaints via service of process.

53 It is of course likely that few juries would find a predominantly improper purpose in any of these cases, but that is beside the point. The mere risk that a jury might find liability, coupled with the low bar the claims need to clear in order to reach a jury in the first place, could become a substantial deterrent to socially beneficial speech and conduct if improper-purpose suits became common. 15 In the First Amendment context, the tendency of a law to deter conduct it does not actually prohibit is known as a chilling effect, and is sometimes sufficient to invalidate the law as an infringement of the freedom of speech even when the object of the law is constitutionally unobjectionable. See Frederick Schauer, Fear, Risk and the First Amendment: Unraveling the "Chilling Ef-feet," 58 B.U. L.REv. 685, 693 (1978).

154 We do not hold that the improper-purpose doctrine actually violates the First Amendment-that question is not before us, and we have no need to reach it. But we are persuaded that the improper-purpose doctrine as it currently exists in Utah is in tension with First Amendment principles, and this tension is a further reason to abandon the precedent on which it is based.

C. The Pratt Dissenters' Concerns Are Adequately Addressed by the Improper Means Prong

* 55 Though the foregoing discussion demonstrates the disadvantages of improper-purpose liability, it does not weigh those costs against the doctrine's benefits-benefits sufficient to persuade two justices of the Pratt court that the improper-purpose prong should be retained despite its dangers. 885 P.2d at 790-91 (Stewart, A.C.J., concurring in the result). 16

1 56 Specifically, two of the Pratt justices argued that although "[the improper-purpose] prong, if construed broadly, could seriously interfere with the forces of competition in the marketplace," the doctrine was nevertheless "sound[ ]." Id. Without an improper-purpose prong, they argued, "infliction of gratuitous harm" might go unremedied. Id. at 790-91. Because of the need for a remedy in cases like Pratt, the two justices preferred to deal with the improper-purpose prong's problems by letting the doctrine mature and narrow itself through the normal processes of common-law adjudication. Id. ("It is, indeed, the strength of the common law that general principles of law receive definition and limitation over time by their application in specific fact situations." (emphasis added)).

T 57 We agree with Justice Stewart's Pratt concurrence that tortious interference law needs flexibility to deal with the new and creative methods people might invent to inflict gratuitous economic harm on each other. But we disagree that improper-purpose liability is the best way to maintain this flexibility. As we explained above, because of the improper-purpose rule's highly fact-dependent character, the doctrine hinders rather than promotes case-by-case efforts to adapt the common law to solve contemporary prob *564 lems. Supra ¶¶ 46-50. Further, the improper-purpose prong's emphasis on defendants' motivations, rather than their actions, prevents courts from articulating clear distinctions between appropriate conduct and conduct that "ought not to be acceptable under the law." Pratt, 885 P.2d at 791 (Stewart, A.C.J., concurring in the result).

158 The better approach is to encourage further development of the improper-means prong. As Justice Stewart's concurrence recognized, "Leigh Furniture did not, and could not, deal with every possible fact situation to which the principles enunciated therein might be applied." Id. at 790. Neither has our improper-means jurisprudence since Leigh Furniture set precise boundaries that will prevent courts from recognizing new sorts of improper means when they arise.

T 59 Further development of the improper-means prong is therefore possible, and it has a great advantage over developing the improper-purpose prong. Unlike findings of improper purpose, findings of improper means will not depend solely on defendants' state of mind. They will thus allow for more careful appellate review, leading to a better defined and more predictable tortious interference jurisprudence.

D. Other Jurisdictions Have Increasingly Limited or Rejected Improper-Purpose Liability

T60 Finally, we observe that we are not alone in determining that improper-purpose liability does more harm than good. In the context of intentional interference with prospective economic relations, one prominent treatise acknowledges "a definite movement toward limiting or even eliminating motive-based liability." 3 Dan B. DosBs ET AL., THE Law or Torts § 639 (2d ed.2011). This movement is not so great as to be irresistible, and much of it depends on a distinction drawn in other states between interference with prospective economic relations and interference with contract. 17

161 Nevertheless, in recent decades a number of courts have concluded that tor-tious interference liability should result from wrongful conduct rather than mere malice. See, e.g., Avilla v. Newport Grand Jai Alai LLC, - R.I. -, 935 AZ2d 91, 99 (2007) ("We do not believe a searching analysis only of motive is in most instances enough to send these cases to the jury. There must still ... be something "illegal about the means employed." (alteration in original)). Some cases have concluded that an improper purpose is sufficient grounds for tortious interference liability only when there is no other reason for the defendant's conduct E.g., Carvel Corp. v. Noonan, 3 N.Y.3d 182, 785 N.Y.S.2d 359, 818 N.E.2d 1100, 1103 (2004) ("[Tortious interference liability] has been recognized where a defendant engages in conduct for the sole purpose of inflicting intentional harm on plaintiffs...." (emphasis added) (internal quotation marks omitted)). Other cases have gone as far as we go here, for similar reasons, and rejected improper purpose liability entirely. E.g., Wal-Mart Stores, Inc. v. Sturges, 52 SW.3d 711, 726 (Tex.2001) ("We ... hold that to recover for tortious interference with a prospective business relation a plaintiff must prove that the defendant's conduct was independently tortious or wrongful.... The concepts of malice [and] justification [i.e., intent] ... provide no meaningful description of culpable conduct. ..." (emphasis added)).

T62 Again, the trend on this point is not irresistible. But we are persuaded that our holding accords with the reasoned judgment of other jurisdictions that have considered the question.

E. Summary

T 63 The improper-purpose doctrine, as it has been articulated in Leigh Furniture and Pratt, has not been successfully restricted within the narrow limits envisioned by Leigh. Rather, it has required fact-finders to look into defendants' souls whenever any evidence of improper purpose could be presented. We now conclude that if the doctrine came into common use, it would deter socially beneficial speech and conduct, and other courts have *565 increasingly sought to solve this problem by restricting or abandoning improper-purpose liability.

T 64 We therefore conclude that the improper-purpose doctrine has not worked well in practice, and that "more good than harm will come by departing from precedent." State v. Menzies, 889 P.2d 393, 399 (Utah 1994). It should therefore be abandoned.

IV. CONSIDERATION OF A DEFENDANTS PURPOSE REMAINS APPROPRIATE IN SOME CIRCUMSTANCES

T 65 Although we reject our past doctrine that improper purpose is sufficient grounds for tortious interference liability, this does not mean that defendants' motives and intent are entirely irrelevant to tortious interference claims. We wish to make clear that defendants' motivation is still relevant to tor-tious interference claims in two ways.

T 66 First and more obviously, tortious interference remains an intentional tort. Leigh Furniture & Carpet Co. v. Isom, 657 P.2d 293, 304 (Utah 1982) ("[Iln order to recover damages, the plaintiff must prove (1) that the defendant intentionally interfered with the plaintiff's existing or potential economic relations...." (emphasis added)). Intent and motive are not synonymous; in the tort context, "intent" means a desire to bring about certain consequences, not a person's reasons for that desire. See REestaTEMENT (SEconp) or Torts § 8A (1965) ("The word 'intent' is used throughout the Restatement of this Subject to denote that the actor desires to cause consequences of his act. ..."). Nevertheless, evidence of defendants' motives will frequently shed light on their intent.

167 Second, defendants' motivation will often be relevant to the improper means prong of the Leigh Furniture test. For example, a plaintiff might bring a tortious interference suit alleging that the defendant's improper means of interference was an abuse of judicial process. See 3 Dan B. Tus Law or Torts § 617 (2d ed.2011) (listing abuse of process as a tort on which a tortious interference claim might be based). In order to adjudicate that claim, a court would have to determine whether the defendant used a legal process "primarily to accomplish a purpose for which .it is not designed." (Gilbert v. Ince, 1999 UT 65, ¶ 17, 981 P.2d 841 (emphasis added) (internal quotation marks omitted). This is only one of many possible claims in which the propriety of a particular means will depend in part on the defendant's reasons for employing it.

T68 In such cases, however, it will never be the defendant's motivation by itself that leads to liability. Abuse of process is an improper means not because the defendant bore the plaintiff ill will; it is an improper means because those who avail themselves of the legal system's coercive powers: have a duty to do so for legitimate legal reasons. A person who violates this duty, with the intent to hinder someone's economic relations, is liable for whatever damages result from that improper act.

169 On the other hand, a person who violates no legal duties, infringes no one's rights, and commits no wrongful action can never be held liable for malice alone.

CONCLUSION

170 For the foregoing reasons, we con-elude that in the absence of any improper means, an improper purpose is not grounds for tortious interference liability. We therefore overrule Pratt v. Prodata, 885 P.2d 786 (Utah 1994). We also disavow all dicta in Leigh Furniture & Carpet Co. v. Isom, 657 P.2d 298 (Utah 1982), that would allow lability based solely on an improper purpose. In order to win a tortious interference claim under Utah law, a plaintiff must now prove "(1) that the defendant intentionally interfered with the plaintiff's existing or potential economic relations, (2) by improper means, (8) causing injury to the plaintiff," Id. at 304.

{71 The Eldridges' tortious interference claims fail the second prong of this test: they have failed to produce evidence of an improper means. The district court's denial of summary judgment on the tortious interference claims is therefore reversed, and the matter *566 is remanded for further action consistent with this opinion.