Mixed Motives = No Evidence

In Alarcon v. Santoyo, the Fifth Court reversed a judgment against a corporate officer, individually, for tortious interference with a contract. Under Holloway v. Skinner, a plaintiff must show that “the defendant officer acted in a fashion so contrary to the entity’s best interests that his actions could only have been motivated by personal interests.” Mixed motives—where an officer’s actions benefit both themselves and the corporation—are insufficient to establish individual liability for tortious interference.

Here, “the fact that Alacorn paid himself a salary as CEO and management fees during this … time period is not sufficient evidence of a personal benefit” from his decisions to pay certain other corporate debts instead of the one involving the plaintiff.  As a result, the Court held that there was no basis for holding the officer individually liable for tortious interference with the contract. 05-24-00297-CV, Aug. 4, 2025.