Innovative Architectural Planners, Inc. v. Ohio Dept. of Adm. Servs.

Citations

• 239 N.E.3d 942
• 2024 Ohio 824

Syllabus

The trial court did not err in granting summary judgment on plaintiff's claims for tortious interference with contract and business relations. An essential element of a tortious interference claim is interference by an outside party to the contract or business relationship, but plaintiff does not name any party that interfered with its contracts and business relationships other than defendants. The trial court did not err in granting summary judgment on plaintiff's claim for civil conspiracy. Because employees of the state of Ohio are all employed by the same legal entity, they cannot conspire with each other under the intracorporate conspiracy doctrine. The trial court did not err in granting summary judgment on plaintiff's claim for quantum meruit because the evidence shows that plaintiff did not confer a benefit on defendant. The trial erred in granting summary judgment on plaintiff's claim for breach of contract. Questions of fact remain regarding whether defendant breached the contract and the amount of damages plaintiff sustained. Moreover, under the continuing breach theory of accrual, plaintiff potentially has timely claims for breach of contract to pursue.