Lewis-Gale Medical Center, LLC v. Alldredge
282 Va. 141
| Va. | 2011Background
- SWEP provided exclusive staffing of Lewis-Gale's Emergency Department; Alldredge, an SWEP physician, was employed 2005–2008 under a 12‑month term with automatic renewal and 90‑day termination notice.
- In March 2008 Alldredge attended a dinner with Lewis-Gale nurses; she did not sign a workers’ letter alleged to concern Lewis-Gale personnel issues.
- Lewis-Gale officials learned of Alldredge's involvement and questioned SWEP about her conduct; emails and meetings followed between Lewis-Gale and SWEP.
- April–May 2008 SWEP board considered terminating Alldredge to protect SWEP’s contract with Lewis-Gale; Alldredge met with Lewis-Gale executives on May 5, 2008.
- SWEP terminated Alldredge under the contract’s 90‑day notice; Alldredge did not report for a shift but SWEP paid salary for three more months.
- Alldredge filed a circuit court complaint alleging tortious interference with her contract with SWEP; Lewis-Gale moved for summary judgment arguing at-will status and lack of improper methods.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Lewis-Gale used improper methods to interfere with SWEP's contract with Alldredge | Alldredge alleged improper methods through intimidation and pretextual actions by Lewis-Gale. | Termination was permitted by the at-will SWEP contract; no improper methods were shown beyond unsavory conduct. | No; actions did not constitute improper methods to sustain tortious interference. |
Key Cases Cited
- Chaves v. Johnson, 230 Va. 112 (1985) (elements of intentional interference with contract; at-will distinctions)
- Dunn, McCormack & MacPherson v. Connolly, 281 Va. 553 (2011) (improper methods include illegal or unethical conduct; limits on malice alone)
- Jae-Woo Cha v. Korean Presbyterian Church of Washington, 262 Va. 604 (2001) (improper methods elements; interference with contract)
- Perk v. Vector Resources Group, 253 Va. 310 (1997) (improper methods involve standards of industry and unethical conduct)
- Maximus, Inc. v. Lockheed Info. Mgmt. Sys. Co., 254 Va. 408 (1997) (improper methods need not be illegal; must be improper under circumstances)
- Goode v. Burke Town Plaza, Inc., 246 Va. 407 (1993) (threats to perform lawful acts are not wrongful; balance of interests)
- Charles E. Brauer Co. v. NationsBank of Va., N.A., 251 Va. 28 (1996) (lawful exercise of contractual rights may incidentally interfere; not actionable per se)
- Williams v. Dominion Tech. Partners, L.L.C., 265 Va. 280 (2003) (not every disrupted contract yields tort liability; need improper methods)