intentional interference claim (Oregon) · Go Syfert
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intentional interference claim in Oregon

14 Oregon opinions name it 2 courts 1989–2025 3 in the last five years

The cases below were cited by Oregon 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.

Followed or applied (8)

CaseFollowedCited
Summerfield v. OLCCgreen
or · 2020 · cited in 2 Oregon opinions naming this issue, 2025–2025
2 sentences

2025Because we ultimately uphold the judgment on the claim for breach of contract, we need not—and do not—discuss the intentional interference claim further. 638 Adelsperger v. Elkside Development LLC found the facts necessary to establish the elements of [the] cause of action”); see also Summerfield v. OLCC, 366 Or 763, 777 , 472 P3d 231 (2020) (“When there is no evidence from which a reasonable trier of fact could find facts sufficient to establish an element of the party’s claim, the opposing party is entitled to a directed verdict on the claim.”).

2025Because we ultimately uphold the judgment on the claim for breach of contract, we need not—and do not—discuss the intentional interference claim further. 638 Adelsperger v. Elkside Development LLC found the facts necessary to establish the elements of [the] cause of action”); see also Summerfield v. OLCC, 366 Or 763, 777 , 472 P3d 231 (2020) (“When there is no evidence from which a reasonable trier of fact could find facts sufficient to establish an element of the party’s claim, the opposing party is entitled to a directed verdict on the claim.”).

22
Lewis v. Oregon Beauty Supply Co.green
or · 1987 · cited in 2 Oregon opinions naming this issue, 1989–2001
2 sentences

2001See Lewis v. Oregon Beauty Supply Co., 302 Or 616, 620-21 , 733 P2d 430 (1987) (holding that an at-will employment contract can form the basis of an intentional-interference claim).

2001See Lewis v. Oregon Beauty Supply Co., 302 Or 616, 620-21 , 733 P2d 430 (1987) (holding that an at-will employment contract can form the basis of an intentional-interference claim).

12
Adelsperger v. Elkside Development LLCgreen
or · 2023 · cited in 1 Oregon opinions naming this issue, 2023–2023
2 sentences

2023Similarly, the majority opinion acknowledges that the intentional interference claim “would only exist if it was determined that Barnett Resorts, LLC was not a successor in interest to Elkside [Resorts LLC] and did not assume the obligations of Elkside’s contracts with the plaintiffs.” 371 Or at 74.

2023The majority opinion called attention to how this claim was pleaded—as an alternative to the breach of contract claim—and framed the issue as whether ORS 63.165 barred a claim asserting that the Barnetts individu- ally (and the LLC) interfered with contracts between plain- tiffs and Elkside. 371 Or at 74.

11
Clemente v. Stategreen
orctapp · 2009 · cited in 1 Oregon opinions naming this issue, 2010–2010
2 sentences

2010See, e.g., Clemente v. State of Oregon, 227 Or App 434, 438-40 , 206 P3d 249 (2009) (declining to consider issue preclusion as an alternate basis for affirmance where that defense had not been set forth in a responsive pleading). 3 Our resolution of this assignment of error also disposes of plaintiffs arguments relating to her claim for defamation against Larson individually. 4 For purposes of determining that Larson was acting within the scope of employment in the intentional interference claim, three requirements must be met.

2010See, e.g., Clemente v. State of Oregon, 227 Or App 434, 438-40 , 206 P3d 249 (2009) (declining to consider issue preclusion as an alternate basis for affirmance where that defense had not been set forth in a responsive pleading). 3 Our resolution of this assignment of error also disposes of plaintiffs arguments relating to her claim for defamation against Larson individually. 4 For purposes of determining that Larson was acting within the scope of employment in the intentional interference claim, three requirements must be met.

11
Banaitis v. Mitsubishi Bank, Ltd.green
orctapp · 1994 · cited in 1 Oregon opinions naming this issue, 2006–2006
2 sentences

2006See Banaitis v. Mitsubishi Bank, Ltd., 129 Or App 371, 382-83 , 879 P2d 1288 (1994), rev dismissed, 321 Or 511 (1995) (the defendant’s ownership of stock in the plaintiffs employer, by itself, did not make the defendant a party to the plaintiff’s employment contract and shield the defendant from liability for interfering with the contract).

2006See Banaitis v. Mitsubishi Bank, Ltd., 129 Or App 371, 382-83 , 879 P2d 1288 (1994), rev dismissed, 321 Or 511 (1995) (the defendant’s ownership of stock in the plaintiffs employer, by itself, did not make the defendant a party to the plaintiff’s employment contract and shield the defendant from liability for interfering with the contract).

11
Banaitis v. Mitsubishi Bank, Ltd.green
or · 1995 · cited in 1 Oregon opinions naming this issue, 2006–2006
1 sentence

2006See Banaitis v. Mitsubishi Bank, Ltd., 129 Or App 371, 382-83 , 879 P2d 1288 (1994), rev dismissed, 321 Or 511 (1995) (the defendant’s ownership of stock in the plaintiffs employer, by itself, did not make the defendant a party to the plaintiff’s employment contract and shield the defendant from liability for interfering with the contract).

11
Ramirez v. Sellesgreen
orctapp · 1989 · cited in 1 Oregon opinions naming this issue, 1994–1994
2 sentences

1994See 96 Or.App. 340 , 772 P.2d 952 (1989).

1994See 96 Or.App. 340 , 772 P.2d 952 (1989).

11
Harm v. Central Life Assurance Co.green
orctapp · 1991 · cited in 1 Oregon opinions naming this issue, 1992–1992
2 sentences

1992See Harm v. Central Life Assurance Co., 107 Or App 708 , 813 P2d 1103 (1991).

1992See Harm v. Central Life Assurance Co., 107 Or App 708 , 813 P2d 1103 (1991).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Oregon. Read the followed side critically anyway.

Also cited on this issue (12)

CaseCitedYears
McGanty v. Staudenraus green
or · 1995
2 sentences

2015Similarly, an intentional interference claim consists of the following elements: “(1) the existence of a professional or business relationship (which could include, e.g., a contract or prospective economic advantage), (2) intentional interference with that relationship, (3) by a third party, (4) accomplished through improper means or for an improper purpose, (5) a causal effect between the interference and damage to the economic relationship, and (6) damages.” McGanty v. Staudenraus, 321 Or 532, 535 , 901 P2d 841 (1995).

2015Similarly, an intentional interference claim consists of the following elements: “(1) the existence of a professional or business relationship (which could include, e.g., a contract or prospective economic advantage), (2) intentional interference with that relationship, (3) by a third party, (4) accomplished through improper means or for an improper purpose, (5) a causal effect between the interference and damage to the economic relationship, and (6) damages.” McGanty v. Staudenraus, 321 Or 532, 535 , 901 P2d 841 (1995).

21995–2015
Adelsperger v. Elkside Development LLC green
orctapp · 2022
2 sentences

2023I would await the final appellate disposition of Adelsperger v. Elkside Development LLC, 322 Or App 809 , 523 P3d 142 (2022) (Adelsperger II), recently decided by the Court of Appeals and involving simi- lar claims from these same plaintiffs,2 before addressing the elder abuse and intentional interference claims in this case.

2023I would await the final appellate disposition of Adelsperger v. Elkside Development LLC, 322 Or App 809 , 523 P3d 142 (2022) (Adelsperger II), recently decided by the Court of Appeals and involving simi- lar claims from these same plaintiffs,2 before addressing the elder abuse and intentional interference claims in this case.

12023–2023
Chesterman v. Barmon green
or · 1988
2 sentences

2010“These requirements traditionally have been stated as: (1) whether the act occurred substantially within the time and space limits authorized by the employment; (2) whether the employee was motivated, at least partially, by a purpose to serve the employer; and (3) whether the act is of a kind which the employee was hired to perform.” Chesterman v. Barmon, 305 Or 439, 442 , 753 P2d 404 (1988) (citations omitted).

2010“These requirements traditionally have been stated as: (1) whether the act occurred substantially within the time and space limits authorized by the employment; (2) whether the employee was motivated, at least partially, by a purpose to serve the employer; and (3) whether the act is of a kind which the employee was hired to perform.” Chesterman v. Barmon, 305 Or 439, 442 , 753 P2d 404 (1988) (citations omitted).

12010–2010
State v. Brown green
or · 1988
1 sentence

2006Rather than determining whether plaintiffs had adduced “some evidence tending to establish each element” of the intentional interference claim, Brown, 306 Or at 602 , the court determined that Mercy had presented more persuasive evidence on the question of causation.

12006–2006
Aylett v. Universal Frozen Foods Co. green
orctapp · 1993
1 sentence

2006Id. at 153 . 8 Paragraph 47 of plaintiffs’ operative fourth amended complaint identifies various “protectible business relationships” for purposes of the intentional interference claim, but does not include any reference to SureCare.

12006–2006
Straube v. Larson green
or · 1979
2 sentences

2006This court followed Wampler in Straube v. Larson, 287 Or 357 , 600 P2d 371 (1979), where it considered an intentional interference claim by a radiologist against a hospital chief administrator who had recommended that the hospital suspend the radiologist’s hospital privileges and other medical staff members who allegedly had conspired in seeking the suspension.

2006This court followed Wampler in Straube v. Larson, 287 Or 357 , 600 P2d 371 (1979), where it considered an intentional interference claim by a radiologist against a hospital chief administrator who had recommended that the hospital suspend the radiologist’s hospital privileges and other medical staff members who allegedly had conspired in seeking the suspension.

12006–2006
Ron Tonkin Gran Turismo, Inc. v. Wakehouse Motors, Inc. green
orctapp · 1980
2 sentences

1995Ron Tonkin Gran Turismo v. Warehouse Motors, 46 Or App 199, 208 , 611 P2d 658 , rev den 289 Or 373 (1980).

1995Ron Tonkin Gran Turismo v. Warehouse Motors, 46 Or App 199, 208 , 611 P2d 658 , rev den 289 Or 373 (1980).

11995–1995
Welch v. Bancorp Management Advisors, Inc. green
or · 1984
2 sentences

1994There, in discussing the privilege of advisors, employees and agents acting on behalf of their principals, which is possibly the most protected of all of the privileges in the law of intentional interference torts, the court made clear that both improper motives and improper means could serve as grounds for the intentional interference claim, see 296 Or. at 715-16, 679 P.2d 866 , and it expressly defined the nature of the improper motive that could overcome that particular privilege ("acts against the best interests of the principal or acts solely for [the agent's] own benefit"). 296 Or. at 21

1994There, in discussing the privilege of advisors, employees and agents acting on behalf of their principals, which is possibly the most protected of all of the privileges in the law of intentional interference torts, the court made clear that both improper motives and improper means could serve as grounds for the intentional interference claim, see 296 Or. at 715-16, 679 P.2d 866 , and it expressly defined the nature of the improper motive that could overcome that particular privilege ("acts against the best interests of the principal or acts solely for [the agent's] own benefit"). 296 Or. at 21

11994–1994
Ramirez v. Selles green
or · 1989
2 sentences

1994In Ramirez v. Selles, 308 Or. 609 , 784 P.2d 433 (1989), the Supreme Court reversed our holding that an intentional interference claim had been properly dismissed under ORCP 21A(8).

1994In Ramirez v. Selles, 308 Or. 609 , 784 P.2d 433 (1989), the Supreme Court reversed our holding that an intentional interference claim had been properly dismissed under ORCP 21A(8).

11994–1994
Sheets v. Knight green
or · 1989
1 sentence

1992Stenbock also argues that the summary judgment was appropriate, because Christman was an at-will employee and because Stenbock was the officer who had the authority to hire and fire. 2 Stenbock argues that Christman, who does not assert a wrongful discharge claim against RMS, see Sheets v. Knight, 308 Or 320 , 779 P2d 1000 (1979), is using an intentional interference claim against him to camouflage his real target, which is RMS.

11992–1992
Giordano v. Aerolift, Inc. neutral
orctapp · 1991
2 sentences

1992We rejected a similar argument in Giordano v. Aerolift, Inc., 109 Or App 122 , 818 P2d 950 (1991), where we held that a “managing officer” can be liable for interference with his principal’s contractual relations with an employee whom he fires with motives that are not intended to serve the principal.

1992We rejected a similar argument in Giordano v. Aerolift, Inc., 109 Or App 122 , 818 P2d 950 (1991), where we held that a “managing officer” can be liable for interference with his principal’s contractual relations with an employee whom he fires with motives that are not intended to serve the principal.

11992–1992
Campbell v. Ford Industries, Inc. green
or · 1976
2 sentences

1989Lewis v. Oregon Beauty Supply Co., supra, 302 Or at 620-21 ; Campbell v. Ford Industries, Inc., 274 Or 243 , 252 & n 8, 546 P2d 141 (1976).

1989Lewis v. Oregon Beauty Supply Co., supra, 302 Or at 620-21 ; Campbell v. Ford Industries, Inc., 274 Or 243 , 252 & n 8, 546 P2d 141 (1976).

11989–1989

Statutes the citing opinions construe

OR § Or. Rev. Stat. § 124.100 (3) OR § Or. Rev. Stat. § 124.110 (3) OR § Or. Rev. Stat. § 164.015 (3)

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.

Where else courts name it

OR 14 (1989–2025) CA 11 (2008–2026) MA 6 (1996–2025) AZ 6 (1995–2021) UT 6 (2015–2025) AL 4 (1998–2009) PA 4 (1997–2024) WA 4 (2005–2021) WY 3 (1986–2022) IL 3 (2008–2023) SC 2 (2009–2021) FL 2 (2023–2024) IA 2 (2019–2022) DE 2 (2021–2025) DC 2 (2012–2013) MD 2 (2010–2020) NJ 2 (1989–1999) WI 2 (2006–2023) LA 2 (1992–2013)

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.

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