Dentist loses defamation and conspiracy claim against competitor and former hygienist

Jason Armstrong, DDS, paid two million dollars to buy a dental practice and then watched as one of the hygienists and a number of patients moved to a competing practice.  Armstrong sued the hygienist and the competitor arguing that they were conspiring to defame him, steal his customers and interfere with his contractual relationships. The Court granted summary disposition to the defendants, holding that Armstrong had not supported his claim with evidence of improper conduct, and that in general he did not "own" his clients' "goodwill."  He had a reasonable expectation of a continuing relationship with client-patients, however, it was his duty to prove wrongful conduct had caused them to migrate to a competitor, and he had offered no proof.  Further, the hygienists own announcement of her move, published in church, was not wrongful and did not expropriate any property owned by Armstrong.