Golden v. Sound Inpatient Physicians Med. Grp. – March 2015 (Summary)

INTERFERENCE WITH CONTRACTUAL RELATIONS

Golden v. Sound Inpatient Physicians Med. Grp., No. 2:14-cv-00497-TLN-EFB (E.D. Cal. Mar. 17, 2015)

The United States District Court for the Eastern District of California dismissed a hospitalist’s suit alleging that a hospitalist group interfered with her prospective economic advantage and violated the state professional code forbidding unfair competition.

The hospitalist had previously held a contract to provide a medical center with her services. After the contract expired, the medical center replaced her with another group. The hospitalist then entered into agreements with several doctors to provide hospitalist services for their patients. The hospitalist provided the medical center with a list of these doctors and requested the medical center to admit their patients under her care. The new group allegedly instructed medical center staff to ignore the list and admit these patients under the care of the new group. The hospitalist brought suit claiming that the new group interfered with her prospective economic advantage and participated in unfair competition.

The court dismissed both claims, holding that the hospitalist did not allege sufficient facts to state a claim that the new group’s conduct rose to the required levels of wrongfulness. The court explained that to interfere with another’s economic relationship, the alleged interfering act must be wrongful by some legal measure. However, the court allowed the hospitalist to amend the complaint to allege the necessary facts.