CRST Van Expedited v. Werner Enterprises, 479 F.3d 1099 (9th Cir. 2007)

CRST sued Werner Enterprises, claiming Werner had interfered with the employment contracts CRST had with two of its truck drivers whom CRST had trained at its expense. The Ninth Circuit reversed the dismissal of CRST’s contractual interference claim on the ground that CRST had properly alleged the necessary elements of such a claim – and that the additional element of an “independently wrongful act” did not have to be alleged because the employees were employed pursuant to a one-year employment contract and were not terminable at will when Werner hired them. Similarly, the Court concluded that CRST had properly alleged a violation of the Unfair Competition Law (California Business & Professions Code § 17200) and, additionally, intentional interference with prospective economic advantage. Finally, the Court affirmed an award of $8,750 in attorney’s fees to Werner under the Uniform Trade Secrets Act on the ground that the trade secrets claim that CRST had initially filed and “informally withdrawn” had been brought in bad faith in violation of California Civil Code § 3426.4.