An at-will employee must show a customer used “improper methods†beyond merely “actions solely motivated by spite, ill will and malice†to prove her employer’s primary customer tortiously interfered with her employment contract, the Virginia Supreme Court has ruled. The Court reversed a jury verdict awarding $900,000 in damages to a doctor for tortious interference, finding the pressure inherent in her employer’s relationship with its customer and primary source of revenue cannot rise to the level of “improper methods†needed for an at-will employee to show that the third party tortiously interfered with her employment contract.
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