In Supinger v. Commonwealth, Case No. 6:15-cv-00017, 2016 WL865332 (W.D. Mar. 2, 2016), the United States District Court for the Western District of Virginia dismissed a tortious interference claim brought by a former employee of the Lynchburg Department of Motor Vehicles’ Law Enforcement Services Office against his former employer. It was one of many different claims brought by the employee alleging generally discrimination and other employment related torts. This is primarily an employment law case but included a short discussion about the tortious interference claim. Specifically, the plaintiff alleged that he had received “conditional offers of employment for positions for which he was qualified” that the defendant interfered with in various respects. The court, however, held that these conditional offers were not sufficient to meet the standard of a “specific, existing contract or business expectancy or opportunity that has been interfered with in a tortious manner.” Id. at *18. The court noted that, after amending his complaint, the plaintiff had offered nothing but conclusory allegations and a formulaic recitation of the elements of the tort, which is not sufficient to state a claim.

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