Where a former law firm employee sued the managing partner for tortious interference, these claims were dismissed. The managing partner could not be held liable for tortious interference with a contract or business expectancy because he and the law firm are the same in the context of these claims.
Iyanna Howard sued her former employee, Glasser & Glasser PLC, and others, including Mark Groves. Count Six for tortious interference with contract and Count Seven for tortious interference with business expectancy arc the only remaining claims in against Groves. Groves has filed a motion to dismiss.
Claims for tortious interference with contract rights or business expectancies “are predicated on the ‘common law duty to refrain from interfering with another’s contractual and business relationships.’” Because a party cannot interfere with his own contract or business expectancy, “a tortious interference claim requires the existence of three actors – the two parties to the contract and a third-party who interferes with, or induces one of the parties to breach, that contract.”
In this case, plaintiff’s claims of tortious interference involve Groves – who plaintiff concedes is a member and managing attorney of the firm. Thus Groves cannot be held liable for tortious interference with a contract or business expectancy because he and the firm are the same in the context of these claims.
Plaintiff argues that Groves can still be held liable for tortious...
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