Marsh v. Anesthesia Servs. Med. Grp., Inc. (Summary)

INTENTIONAL INTERFERENCE WITH PROSPECTIVE ECONOMIC ADVANTAGE

Marsh v. Anesthesia Servs. Med. Grp., Inc., D064024 (Cal. Ct. App. June 6, 2014)

A California appellate court reversed a lower court’s ruling that was in favor of a physician group that dismissed an anesthesiologist’s claims of intentional interference with prospective economic advantage.

 The anesthesiologist’s claim of intentional interference with prospective economic advantage was predicated on defamatory statements allegedly made by the group.  The anesthesiologist argued that these statements had caused two plastic surgeons to stop using her services, causing her economic harm.

 The lower court had dismissed the anesthesiologist’s claim, ruling that she had not adequately linked the group’s defamatory statements with the plastic surgeons’ decision to stop using her services.  The California appellate court reversed this part of the lower court’s decision, concluding that the anesthesiologist had adequately linked the conduct of the plastic surgeons with the statements made by the group, and that she could continue her lawsuit for intentional interference with prospective economic advantage.