AFM Corp. v. Southern Bell Tel. & Tel.

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• noting that ‘“a breach of contract, alone, cannot constitute a cause of action in tort.... It is only when the breach of contract is attended by some additional conduct which amounts to an independent tort that such breach can constitute negligence’ ”
• finding no basis for recovery in negligence where plaintiff had not proved a tort independent of the breach of contract
• “without some conduct resulting in personal injury or property damage, there can be no independent tort flowing from a contractual breach which would justify a tort claim solely for economic losses”
• “We conclude that without some conduct resulting in personal injury or property damage, there can be no independent tort flowing from a contractual breach which would justify a tort claim solely for economic losses.” (emphasis supplied)
• extending economic-loss doctrine to contract for advertising services

Source: CourtListener parenthetical corpus (CC0).