California, United States of America
The following excerpt is from Pifer v. Pifer, D072582 (Cal. App. 2018):
In Mintz v. Blue Cross of California, supra, 172 Cal.App.4th 1594, the court explained that the " 'agent's immunity rule' " means that " 'duly acting agents and employees cannot be held liable for conspiring with their own principals . . . .' " (Id. at p. 1605.) This rule applies only to claims of conspiracy to commit a tort, and "has no direct applicability to a claim for interference with contract rights." (Ibid.) There, the court said the real question was "whether the representative of a contracting party may be held liable for the substantive tort of interfering with the contract. The cases answer that question in the negative." (Id. at p. 1606.)
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