Doctors acting for their own benefit aren't guilty of tortious interference
Grand Valley Health Corporation sued James E. Bakeman, M.D. and Donald R. Bohay, M.D., alleging that they tortiously interfered with the Corporation's business relationship with the doctors' medical practices by inducing changes in the member physicians' referral patterns. The Court held that only a "third-party" can be guilty of tortious interference. Since the two doctors were members of the practice that they were inducing to change, they could not commit the alleged offense.