Petkanas v. Kooyman

In Petkanas v. Kooyman, 303 AD2d 303 (1st Dept. 2003), it was ruled: "A cause of action seeking to hold corporate officials personally responsible for the corporation's breach of contract is governed by an enhanced pleading standard. Generally, we have construed such a standard to require a particularized pleading of allegations that the acts of the defendant corporate officers which resulted in the tortious interference with contract either were beyond the scope of their employment or, if not, were motivated by their personal gain, as distinguished from gain for the corporation. We have construed personal gain in terms that the challenged acts were undertaken with malice and were calculated to impair the plaintiff's business for the personal profit of the individual defendant".