Painter's Mill Grille, LLC v. Howard Brown

How courts have described this case

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

• holding that conclusory and speculative allegations that the landlord interfered with restaurant’s ability to contract with customers, through conduct motivated by racial animus, were insufficient to state a claim under Section 1981
• finding that “mere conclusory and speculative allegations” are insufficient to survive a Rule 12(b)(6) motion to dismiss
• stating that the doctrine does not apply where employees are motivated solely by personal bias
• holding individual plaintiff business owners cannot bring claim under § 1981 for interference in contract between the business and its customers because the owners had no rights under the contracts with the customers
• explaining that Plaintiffs, by “elect[ing] to conduct their business through [an LLC] . . . gave up standing to claim damages to the LLC, even if they also suffered personal damages as a consequence.”
• holding LLC members lacked standing to bring claims for tortious interference with contract when they were not parties to the contract and the injuries suffered derived entirely from the injury their company allegedly sustained

Source: CourtListener parenthetical corpus (CC0).