S. Health Corp. of Hous. v. Crausby – May 2015 (Summary)

TORTIOUS INTERFERENCE

S. Health Corp. of Hous. v. Crausby, No. 2014-CA-00603-COA (Miss. Ct. App. May 26, 2015)

The Court of Appeals of the State of Mississippi reversed a jury’s finding that a hospital and its administrators conspired to tortiously interfere with an emergency room nurse’s employment relationship by acquiescing to the demand of the chief of staff that the nurse be fired. However, the court affirmed the jury’s finding that the chief of staff slandered the nurse by making false allegations against her to hospital administrators.

The court held no conspiracy existed because firing the nurse was not an unlawful purpose, nor was it a lawful purpose accomplished by unlawful means. In affirming the jury’s finding that the chief of staff slandered the nurse, the court rejected his argument that the comments he made to the administrators about the nurse were protected by a qualified privilege. Although the court found that the chief of staff was commenting on the emergency room in which he occasionally worked, the court held the jury was entitled to believe that his comments were made with malice, sufficient to overcome the qualified privilege.