Reeves

Reeves v. Hanlon

Bad Law
17 Cal. Rptr. 3d 289·2004 Cal. LEXIS 7239·2004 Daily Journal DAR 9911·33 Cal. 4th 1140·95 P.3d 513
Supreme Court of CaliforniaAugust 12, 2004S114811California5,630 words

Opinion

Opinion

Baxter, J.

The primary issue presented is whether a defendant may be held liable under an intentional interference theory for having induced an at-will employee to quit working for the plaintiff. Because an interference as such is primarily an interference with the future relation between the plaintiff and the at-will employee, we hold that inducing the termination of an at-will employment relation may be actionable under the standard applicable to claims for intentional interference with prospective economic advantage. Accordingly, to recover for a defendant’s interference with an at-will employment relation, a plaintiff must plead and prove that the defendant engaged in an independently wrongful act—i.e., an act “proscribed by some constitutional, statutory, regulatory, common law, or other determinable legal standard” (Korea Supply Co. v. Lockheed Martin Corp. (2003) 29 Cal.4th 1134, 1159 [ 131 Cal.Rptr.2d 29 , 63 P.3d 937 ] (Korea Supply))—that induced the at-will employee to leave the plaintiff.

Adopting this standard of recovery in the context of at-will employment relations is particularly appropriate. Not only will it guard against unlawful methods of competition in the job…

Sign in to read the full opinion

Create a free account to read the complete opinion text, citation history, and good-law status for this case.