In Miles Farm Supply, LLC v. Helena Chem. Co., No. 08-6093, the Sixth Circuit dealt with the issue of whether defendant aided and abetted plaintiff's employees to breach their fiduciary duties, and was thus liable for tortious interference with plaintiff's prospective contractual relations.
Unlike the reasoning the district court used in reaching its decision to grant summary judgment in favor of the defendants, the court clarified that the more appropriate ground was whether defendant knew about the employees' alleged breach, not whether the employees breached a fiduciary duty.
Thus, based on the evidence, the court held that plaintiff failed as a matter of law to show that defendant had actual knowledge that the three employees were breaching a fiduciary duty.