“[U]nder Massachusetts law, the tort of interference with an advantageous business relationship apparently includes within its ambit the tort of wrongful interference with an existing contract[.]” Hamann v. Carpenter, 937 F.3d 86, 92-93 (1st Cir. 2019). Where, as here, “the plaintiff sues an official of the employer, [she] must satisfy an additional element: that the supervisor acted with ‘actual malice.'” Eaton v. Town of Townsend, No. 18-11824-LTS, 2022 WL 952189, *24 (D. Mass. Mar. 30, 2022), aff'd, No. 221334, 2023 WL 3317986 (1st Cir. May 9, 2023) (quoting Zimmerman v. Direct Fed. Credit Union, 262 F.3d 70, 75 (1st Cir. 2001)). “Proof of actual malice requires more than a showing of mere hostility[,]” and a plaintiff must “demonstrate that spite or malevolence, i.e., a purpose unrelated to any legitimate corporate interest, was the controlling factor” in engaging in the challenged conduct. Id. (quoting Alba v. Sampson, 44 Mass.App.Ct. 311, 315, 690 N.E.2d 1240, 1243 (1998)) (emphasis omitted).
In the employment context, where "the plaintiff sues an official of the employer, [she] must satisfy an additional element: that the supervisor acted with ‘actual malice.’ " Eaton v. Town of Townsend, Civil No. 18-11824-LTS, 2022 WL 952189, *24 (D. Mass. March 30, 2022) (quoting Zimmerman v. Direct Fed. Credit Union, 262 F.3d 70, 75 (1st Cir. 2001) ). "Proof of actual malice requires more than a showing of mere hostility."
In the employment context, where "the plaintiff sues an official of the employer, [she] must satisfy an additional element: that the supervisor acted with ‘actual malice.’ " Eaton v. Town of Townsend, Civil No. 18-11824-LTS, 2022 WL 952189, *24 (D. Mass. March 30, 2022) (quoting Zimmerman v. Direct Fed. Credit Union, 262 F.3d 70, 75 (1st Cir. 2001) ). "Proof of actual malice requires more than a showing of mere hostility."