When talking about the practice of law with other lawyers—whether long-time practitioners, first-year associates, or any stage in between—I have been known to advocate for my chosen practice area by pointing out that employment lawyers never get bored with the fact patterns we encounter. I am of course willing to acknowledge that other commercial litigators surely come across an exciting case occasionally, but employment lawyers routinely deal with allegations that at the very least are interesting and sometimes include personality conflicts that are akin to a soap opera. In late February, the Pennsylvania Supreme Court issued a decision in Salsberg v. Mann, — A.3d —- (2024), that could help to ensure that employment litigation will continue to have the "best" fact patterns for years to come, when it ruled that plaintiffs can maintain a cause of action for intentional interference with an at-will employment relationship against third parties, including co-workers who act outside the scope of their authority to the point they are rendered a "stranger" to the plaintiff's at-will employment relationship with their employer.

Drexel University employed Cara Salsberg as its tax manager; an at-will position within the university's tax department. Salsberg reported to Donna Mann, whose supervisory responsibilities included determining Salsberg's schedule and assignments, evaluating Salsberg's performance, and making recommendations to the university related to Salsberg's employment. During a staff meeting in anticipation of the 2017 tax season, Mann told Salsberg and another tax department employee that they would soon need to work a yet-to-be-determined amount of overtime during the upcoming "busy season." Salsberg expressed her disagreement to Mann, who in turn blamed her own supervisor, David Rusenko, for the increased workload. Salsberg then decided to meet with Rusenko directly. During her meeting with Rusenko, Salsberg addressed the mandatory overtime issue but also raised additional alleged "concerning" behaviors about Mann. She claimed that Mann "did nothing all day" and was "crazy." She also told Rusenko that Mann would regularly "pick her head until it bled," and "run through the office," bump into walls, and slam her office door. Rusenko declined to intervene and instead recommended that Salsberg address these matters with Mann directly. Shortly after Salsberg did so, Mann issued Salsberg a performance improvement plan. In early June 2017, Drexel terminated Salsberg's employment for poor performance.