21 Massachusetts opinions name it 3 courts 1994–2025 2 in the last five years
The cases below were cited by Massachusetts courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
United Truck Leasing Corp. v. Geltmangreen2 sentences2016See, e.g., King v. Driscoll, 418 Mass. 576, 587 (1994) (“The motivation of personal gain, including financial gain, . . . generally is not enough to satisfy the improper interference requirement”); United Truck Leasing Corp. v. Geltman, 406 Mass. 811, 817 (1990) (similar). 2012“The motivation of personal gain, including financial gain... generally is not enough to satisfy the improper interference requirement.” King v. Driscoll, 418 Mass. 576, 587 (1995); United Truck, 406 Mass. at 817 . | 6 | 8 |
King v. Driscollgreen2 sentences2016See, e.g., King v. Driscoll, 418 Mass. 576, 587 (1994) (“The motivation of personal gain, including financial gain, . . . generally is not enough to satisfy the improper interference requirement”); United Truck Leasing Corp. v. Geltman, 406 Mass. 811, 817 (1990) (similar). 2013“The motivation of personal gain, including financial gain . . . generally is not enough to satisfy the improper interference requirement.” King v. Driscoll, 418 Mass. 576, 587 (1995); United Truck, 406 Mass, at 817. | 6 | 8 |
Weber v. Community Teamwork, Inc.green2 sentences2016It is not “personal hostility or ill will,” or a “ ‘spiteful, malignant purpose’ that is unrelated to a legitimate [corporate] interest [of the employer].” Anzalone v. Administrative Office of Trial Court, 457 Mass. 647, 660-61 (2010); Weber v. Community Teamwork, Inc., 434 Mass. 761, 782 (2001). 7 This is an elemental failure of the claim. 2006Weber v. Community Teamwork, Inc., 434 Mass. 761, 781 (2001). | 2 | 2 |
Deutsche Bank National Ass'n v. First American Title Insurancegreen1 sentence2025Cf. Metropolitan, 460 Mass. at 358–359; accord Deutsche Bank, 465 Mass. at 745 . | 1 | 1 |
Robinson v. Magoverngreen1 sentence2025See, e.g., Robinson, 83 F.R.D. at 85 . | 1 | 1 |
Romero v. UHS of Westwood Pembroke, Inc.green1 sentence2019See Romero , 72 Mass. App. Ct. at 548 . | 1 | 1 |
Anzalone v. Administrative Office of the Trial Courtgreen1 sentence2016It is not “personal hostility or ill will,” or a “ ‘spiteful, malignant purpose’ that is unrelated to a legitimate [corporate] interest [of the employer].” Anzalone v. Administrative Office of Trial Court, 457 Mass. 647, 660-61 (2010); Weber v. Community Teamwork, Inc., 434 Mass. 761, 782 (2001). 7 This is an elemental failure of the claim. | 1 | 1 |
Boothby v. Texon, Inc.green1 sentence2013Boothby v. Texon, Inc., 414 Mass. 468, 487 (1993); United Truck Leasing Corp. v. Geltman, 406 Mass. 811, 817 (1990). | 1 | 1 |
Lopez v. Commonwealthgreen1 sentence2013See Lopez v. Commonwealth, 463 Mass. 696, 706 (2012) (defendant “need not be an employer to be subject to an interference claim under § 4[4A]”); Thomas O’Connor Constructors, Inc. v. Massachusetts Commn. | 1 | 1 |
Berkshire Armored Car Services, Inc. v. Sovereign Bank of New Englandgreen1 sentence2013See also Berkshire Armored Car Services, Inc. v. Sovereign Bank of New England, 65 Mass.App.Ct. 96, 102-03 (2002) (conduct motivated by desire to advance a party’s business interest is not improper). | 1 | 1 |
Thomas O'Connor Constructors, Inc. v. Massachusetts Commission Against Discriminationgreen1 sentence2013Against Discrimination, 72 Mass. App. Ct. 549, 554-560 (2008) (employee of a subcontractor permitted to sue general contractor). | 1 | 1 |
Comey v. Hillgreen1 sentence2012See also Comey v. Hill 387 Mass. 11, 19-20 (1982) (action based on age discrimination supported jury verdict for plaintiff on intentional interference claim); Draghetti v. Chimielewski, 416 Mass. 808, 817 (1994); Martins v. University of Mass. Medical Sch., 75 Mass.App.Ct. 623, 634 (2009) (holding that interference claim against supervisors should have been submitted to jury in conjunction with discrimination claims); Steranko v. Irforex, Inc., 5 Mass.App.Ct. 253, 273 (1977) (“Discrimination constitutes an improper means or motive for purposes of an interference claim and constitutes actual ma | 1 | 1 |
Draghetti v. Chmielewskigreen1 sentence2012See also Comey v. Hill 387 Mass. 11, 19-20 (1982) (action based on age discrimination supported jury verdict for plaintiff on intentional interference claim); Draghetti v. Chimielewski, 416 Mass. 808, 817 (1994); Martins v. University of Mass. Medical Sch., 75 Mass.App.Ct. 623, 634 (2009) (holding that interference claim against supervisors should have been submitted to jury in conjunction with discrimination claims); Steranko v. Irforex, Inc., 5 Mass.App.Ct. 253, 273 (1977) (“Discrimination constitutes an improper means or motive for purposes of an interference claim and constitutes actual ma | 1 | 1 |
Ashcroft v. Iqbalgreen1 sentence2012See Ashcroft v. Iqbal, 556 U.S. 662, 679 (2009) (plausibility standard requires “context-specific” inquiry that asks court to “draw on its judicial experience and common sense”); Twombly, supra at 554-556 (“Asking for plausible grounds to infer an agreement does not impose a probability requirement at the pleading stage; it simply calls for enough fact to raise a reasonable expectation that discovery will reveal evidence of illegal agreement”). 20 It was not necessary that the plaintiffs allege that use of the division’s examination led to a disparate impact on promotions in any particular, id | 1 | 1 |
Bell Atlantic Corp. v. Twomblygreen1 sentence2012See Ashcroft v. Iqbal, 556 U.S. 662, 679 (2009) (plausibility standard requires “context-specific” inquiry that asks court to “draw on its judicial experience and common sense”); Twombly, supra at 554-556 (“Asking for plausible grounds to infer an agreement does not impose a probability requirement at the pleading stage; it simply calls for enough fact to raise a reasonable expectation that discovery will reveal evidence of illegal agreement”). 20 It was not necessary that the plaintiffs allege that use of the division’s examination led to a disparate impact on promotions in any particular, id | 1 | 1 |
Sahli v. Bull HN Information Systems, Inc.green1 sentence2012Sys., Inc., 437 Mass. 696, 700 (2002), where an employer brought a declaratory judgment action against a former employee who, after signing a release of liability, had brought an age discrimination claim against the employer. | 1 | 1 |
Bray v. Community Newspaper Co.green1 sentence2012“Discrimination constitutes an improper means or motive for purposes of an interference claim, and constitutes actual malice that, if proved, would defeat the [defendant’s] conditional privilege.” Bray v. Community Newspaper Co., 67 Mass.App.Ct. 42, 48 (2006) (reversing grant of summary judgment where there was evidence that defendants subjected plaintiff to pattern of age discrimination, causing her to resign from her job). 6 There is a genuine issue of material fact as to Prouty’s malicious involvement in Haraden’s termination and denial of reemployment while she worked at Verizon. | 1 | 1 |
Martins v. University of Massachusetts Medical Schoolgreen1 sentence2012See also Comey v. Hill 387 Mass. 11, 19-20 (1982) (action based on age discrimination supported jury verdict for plaintiff on intentional interference claim); Draghetti v. Chimielewski, 416 Mass. 808, 817 (1994); Martins v. University of Mass. Medical Sch., 75 Mass.App.Ct. 623, 634 (2009) (holding that interference claim against supervisors should have been submitted to jury in conjunction with discrimination claims); Steranko v. Irforex, Inc., 5 Mass.App.Ct. 253, 273 (1977) (“Discrimination constitutes an improper means or motive for purposes of an interference claim and constitutes actual ma | 1 | 1 |
Steranko v. Inforex, Inc.green1 sentence2012See also Comey v. Hill 387 Mass. 11, 19-20 (1982) (action based on age discrimination supported jury verdict for plaintiff on intentional interference claim); Draghetti v. Chimielewski, 416 Mass. 808, 817 (1994); Martins v. University of Mass. Medical Sch., 75 Mass.App.Ct. 623, 634 (2009) (holding that interference claim against supervisors should have been submitted to jury in conjunction with discrimination claims); Steranko v. Irforex, Inc., 5 Mass.App.Ct. 253, 273 (1977) (“Discrimination constitutes an improper means or motive for purposes of an interference claim and constitutes actual ma | 1 | 1 |
Harrison v. NetCentric Corp.green1 sentence2010Hallowell replies that wrongful procurement of termination, even of an at-will employee, may satisfy the “improper motive or means” element of the interference claim, citing, inter alia, Harrison v. NetCentric Corp., 433 Mass. 465, 477 (2001). | 1 | 1 |
Adcom Products, Inc. v. Konica Business Machines USA, Inc.green1 sentence2010King v. Driscoll 418 Mass. 576, 587 (1994); see United Truck Leasing Corp. v. Geltman, 406 Mass. 811, 817 (1990) (where defendant’s motives were to benefit his customers and himself financially and not to hurt the plaintiff, tortious interference claim could not be sustained); Adcom Products, Inc. v. Konica Business Machines USA, Inc., 41 Mass.App.Ct. 101, 105 (1995) (improper motive consists of a desire to harm the plaintiff). | 1 | 1 |
McNamee v. Jenkinsgreen1 sentence2003See McNamee v. Jenkins, 52 Mass. App. Ct. at 508 (element of claim is that the “loss of the advantage” resulted from defendant’s conduct). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Massachusetts. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Metropolitan Property & Casualty Insurance Co. v. Morrison
green
1 sentence2025Cf. Metropolitan, 460 Mass. at 358–359; accord Deutsche Bank, 465 Mass. at 745 . | 1 | 2025–2025 |
Griggs v. Duke Power Co.
green
1 sentence2012What Congress has forbidden is giving these devices and mechanisms controlling force unless they are demonstrably a reasonable measure of job performance.” Griggs, supra at 436 . 19 We decide today that, like a claim under § 4 (1), see note 16, supra, an interference claim under § 4 (4A) may be established by evidence of disparate impact. | 1 | 2012–2012 |
Sibley Memorial Hospital v. Verne Wilson
green
1 sentence2008O’Connor is a covered employer under c. 151B. 1 Identical language in the Federal antidiscrimination statute, Title VB of the Civil Rights Act of 1964, 42 U.S.C. § 2000e-2(a)(1) (2006), has been virtually uniformly construed over the past thirty-five years to provide for an interference claim, starting with Judge McGowan’s decision for the United States Court of Appeals for the District of Columbia Circuit in 1973 in Sib ley Memorial Hosp. v. Wilson, 488 F.2d 1338 (D.C. | 1 | 2008–2008 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.