Proving ''reasonable Expectancy Of Employment'' With A Third Party In Intentional Interference With Prospective Economic Advantage Claims
Does an Individual Have to Prove Reasonable Expectancy of Employment With a Third Party to State a Claim for Intentional Interference with Prospective Economic Advantage ?
In Werblood v. Columbia College of Chicago, 180 Ill. App. 3d 967, 536 N.E.2d 750, 129 Ill. Dec. 700 (1989), appeal denied, 127 Ill. 2d 644, 545 N.E.2d 134 (1989), a former faculty member brought an action for intentional interference with prospective economic advantage against the college's trustees, president and dean, alleging that the method by which her employment was terminated "stigmatized" her and interfered with her ability to find suitable employment at other institutions in the area. Werblood, 180 Ill. App. 3d at 970.
The trial court dismissed the plaintiff's claim, and the plaintiff appealed. Werblood, 180 Ill. App. 3d at 971.
On appeal, the defendants argued that the plaintiff's claim was factually insufficient because she failed to allege that she had a reasonable expectancy of employment with a third party. Werblood, 180 Ill. App. 3d at 975.
The Werblood court agreed, stating:
"In order to 'state a claim for intentional interference 'with prospective economic advantage, a plaintiff must allege inter alia that 'any clearly identifiable group of third parties contemplated prospective contractual arrangements with the plaintiff.'
The plaintiff fails to allege that any institution of higher education in the Chicago area contemplated or contemplates employment of the plaintiff in her chosen field, nor does the plaintiff allege that she has attempted to seek, employment at any institution of higher education in the Chicago area.
Consequently the plaintiff's claim is factually insufficient and was properly dismissed by the trial court." Werblood, 180 Ill. App. 3d at 975.