Wolf v. F & M Banks
In Wolf v. F & M Banks, 193 Wis. 2d 439, 534 N.W.2d 877 (Ct. App. 1995), in which a bank president brought claims, including tortious interference with contract, against two employees as a result of their respective roles in bringing a sexual harassment complaint against him, this court declared that the plaintiff's claim, to survive the "conditional privilege" accompanying such a complaint, would have to be supported by evidence of "ill will or an improper motive towards the plaintiff." See id. at 462.
Further, the Court emphasized:
"To not recognize the conditional privilege in such a setting would frustrate an employer's attempt to investigate and correct employee-related problems in the workplace. It would also chill an employee's willingness to freely and openly discuss the matter in such a setting." 193 Wis. 2d at 460-61.