§37.2 Parent Inducing Wholly-Owned Subsidiary
The Case: Waste Conversion Systems v. Greenstone Industries , Inc., 33 S.W.3d 779 (Tenn. 2000).
The Basic Facts: Plaintiff, the seller of waste paper, brought a federal claim against a buyer's parent corporation asserting the parent corporation willfully and maliciously induced the subsidiary to breach a contract between Plaintiff and the subsidiary.
The Bottom Line:
Other Sources of Note: Freeman Management Corp. v. Shurgard Storage Centers, LLC , 461 F.Supp.2d 629, 638 (M.D. Tenn. 2006) (holding that a parent company did not demonstrate a sufficient unity of interest under Waste Conversion to warrant the parent-subsidiary privilege); Cambio Health Solutions, LLC v. Reardon, 213 S.W.3d 785, 792 (Tenn. 2006) (declining to extend Waste Conversion and holding that "the privilege of a parent corporation to interfere with the contractual relations of a subsidiary corporation does not apply when the parent owns less than 100% of its subsidiary.").