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THE LAW OF MOTION PICTURES
defendant in inducing the actor to breach his contract were immaterial so long as the means used by him in inducing the breach were legal, and plaintiff had no cause of action against defendant.237
The other two actions were brought in equity. In Jesse L. Lasfoy Feature Play Co. v. Fox the complaint alleged that plaintiffs had made a contract with an actress of unique and extraordinary ability whereby she had agreed to pose for plaintiffs in the making of motion pictures for a specified period; that defendant by making false representations had induced her to breach the contract; that the false representations consisted of statements to her that the contract between plaintiffs and her was void, that plaintiffs had no intention of furnishing her with employment as provided for in the contract, that plaintiffs had violated the agreement in failing to make the necessary preparations for posing and that she was under no obligation to perform the agreement. The contract contained a negative covenant. The defendant, who was a business rival of plaintiffs, had caused the actress to pose for a motion picture subsequent to the making of the above mentioned agreement and prior to its termination; and the relief asked for was, among other things, for an injunction restraining defendant from exhibiting the photo-play for which the actress had posed.
237 Bourlier Bros. v. Macauley involves legal recognition of per(1891), 91 Ky. 135; 15 S. W. 60. sonal dominion, bordering on “. . . For, to enforce a doctrine pure servitude, which is neither making the hirer responsible for in harmony with our form of breach by the person hired of a government nor well for those previous contract with another who labor for subsistence. . . .”