§ 6.2.10 EVIDENCE OF A BREACH OF EMPLOYMENT CONTRACT REQUIRED.

• Jurisdiction: Arizona

§ 6.2.10 Evidence of a Breach of Employment Contract Required. Courts will dismiss claims for tortious interference with contractual relations absent some evidence that the alleged improper conduct actually caused a breach or termination of an employment contract.

In Stingley v. State of Arizona,⁹⁵ a hostile work environment claim brought by a state corrections employee, the court dismissed the plaintiff's tortious interference with contract claim after concluding that there was no evidence that the defendants succeeded in interfering with the plaintiff's employment relationship with the state.

The court reached a similar conclusion in Boatman v. Samaritan Health Services, Inc.⁹⁶ Three pilots employed by a helicopter ambulance service sued a hospital that contracted with the service for claims including intentional interference for contract. Plaintiffs alleged that the hospital interfered with their employment by insisting that the service perform its contract according to a term in the contract requiring that the service provide three pilots for a single helicopter. The plaintiffs argued that it was...