In Allen v. Hall, 328 Ore. 276, 281, 974 P.2d 199 (1999), the plaintiffs alleged that in the months before his death, Putman drafted a will devising most of his property to the defendants, on whom he depended on for assistance with his health and finances. Shortly thereafter, Putman met with an attorney to draft and execute a new will leaving some real estate to the plaintiffs. However, before Putman was able to execute the new will, the defendants learned of his efforts to change his will. They immediately placed him in a hospital and prevented him from communicating with his attorney to execute the new will before he died. Allen, 328 Ore. at 278-80. The Oregon Supreme Court held that "an intentional interference with a prospective inheritance may be actionable under a reasonable extension of the well-established tort known as intentional interference with economic relations." 328 Ore. at 280. In Allen, the plaintiffs alleged that, but for the defendants' interference, they would have inherited certain property from the estate of George Putman. The plaintiffs were not named beneficiaries of Putman's will, but they alleged facts that demonstrated that they almost certainly would have been were it not for the defendants' interference. On certification from the Ninth Circuit, the Supreme Court held that the plaintiffs had stated a claim for intentional interference with economic relations.