Tortious Interference / Emotional Distress Claim Stemming from Business Breakup, with Autism Spectrum Elements

From Lakefront Pictures, LLC v. Ancel, decided today by Judge Jeffrey Cummings (N.D. Ill.) (Jennifer Karum appears to be also known professionally as Jennifer Goodman, for more on The Unseen, see here); note that there's no defamation claim here, and it's not clear to me that the tortious interference claim would require a showing of falsehood:

The facts below are drawn from the allegations in the Complaint …. Plaintiff Jennifer Karum ("Karum") is an actor, writer, and filmmaker, and is the founder of plaintiff Lakefront Pictures, LLC ("Lakefront")—a film production company. Through her work, Karum—who is neurodiverse and on the autism spectrum—seeks to support and promote other neurodiverse artists, who, as a group, are underrepresented in the film industry.

In 2020, Karum began working on the script for her first feature length film titled "The Unseen." Lakefront pre-cast defendant Candice Rose ("Rose")—whom Karum knew and had worked with previously—as one of the major roles in the film. Over a year after the project started, Lakefront reached out to defendant Jordan Ancel ("Ancel") about potentially serving as a film producer. Although Ancel initially expressed "no interest" in the project, on May 31, 2021 he (through his company, defendant Rock City Road Films, LLC) entered into a Producer Agreement with plaintiff The Curse, LLC, a special purpose entity managed by Lakefront that owned the intellectual property rights related to The Unseen. Ancel, through defendant Jordan Ancel International, LLC, also executed a non- disclosure agreement with Lakefront….

Despite Ancel's "positive first impression," plaintiffs allege that he became "largely disengaged" with the project and ultimately "failed to perform competently or professionally." For example, Ancel confided in Karum about his extra-marital affairs, and abdicated his responsibilities on set to pursue a female crew member. Karum attempted to admonish Ancel for his behavior, and as the relationship soured, Ancel began to threaten Karum. For example, in a text message exchange, after Karum brought up whether Ancel's wife was aware of his extra-marital affairs, Ancel responded "If you bring that up, I'm gonna fly to Chicago and you're gonna fucking regret it."

On other occasions, Ancel would try to "weaponize Karum's autism" by buylling her— often times in front of the cast and crew in an attempt to embarrass her and incite division on set. In still other instances, Ancel would "cruelly mock Karum's autism telling her and others" that Karum used her autism as "a crutch to excuse or justify her actions." …

After the filming of The Unseen ended, Lakefront advised Ancel that his services would no longer be necessary, relieving him of any post-production responsibilities. Ancel became irate at his de facto termination and sent Karum a barrage of texts referencing his desire to "burn her life down" and "ruin" her company, calling her a "fucking moron" and "stupid motherfucker," telling her that her autism was an excuse for her "shitty behavior," "poor decision making," and "incompetence," and clarifying that he would "come after [Karum] for everything [she had]. Everything."

Ancel further responded by "telling anyone who would listen that Karum was 'dangerous'" and that she had "baselessly accused him of sexual assault"—which Karum denies. Ancel then commenced a lawsuit against Karum, repeating the allegation that Karum wrongly accused him of sexual assault. Ancel disseminated his complaint on social media and boasted to third-parties that he had a strategy for "taking down Karum in an epic way." Ancel also began to falsely represent across social media that there was a class action suit against Karum and Lakefront in the works, in an effort to mislead people into believing Karum had a history of making false accusations.

Ancel and his supporters also launched a cyberbullying or "smear" campaign against Karum and Lakefront. For example, whenever someone promoted a project with Lakefront, they were bombarded with messages and/or communications claiming that Karum and/or Lakefront were "dangerous" and that Karum was disfavored in the Chicago film community. Rose—who, again, was an actor in The Unseen—also contributed to the smears against Karum and Lakefront, despite the fact that she was never on set with Karum because their respective scenes were shot at different times.

Similar smears were sent "anonymously to [Lakefront's] clients, prospects and partners using Gmail accounts under fictitious or truncated names to avoid detection." As a result of the smear campaign, several Lakefront clients canceled their contracts with the company. Per the Complaint, Ancel was behind these "orchestrated" attacks.

Plaintiffs sued, and the court allowed their claims to go forward. As to tortious interference with a business relationship, the court reasoned:

To prevail on a claim for tortious interference under Illinois law, a plaintiff must show: "(1) they had a reasonable expectancy of entering into a valid business relationship, (2) the [defendants] knew of the expectancy, (3) the [defendants] intentionally and unjustifiably interfered with the expectancy, inducing or causing a breach or termination, and (4) they suffered damage as a result."…

The Court agrees with plaintiffs and finds that they have pleaded sufficient facts concerning the intent element of their claim for tortious interference. In particular, plaintiffs allege that Ancel sent "smears"—at times anonymously or through others—to Lakefront's "clients, prospects and partners." Plaintiff also attaches screenshots of various social media messages and emails that Ancel, or someone at his direction, sent to entities or individuals calling Karum and Lakefront "unsavory," warning them to "beware," and stating that they will "most likely be deposed" if they work on plaintiffs' projects.

Ancel's "smear campaign and direct acts," plaintiffs allege, were "inten[ded] to cause "reputational and economic harm," and have "caused the termination of [plaintiffs'] contracts, and prevented the prospective contracts and relationships from being solidified."

As such, plaintiffs have sufficiently alleged that defendants intentionally and unjustifiably interfered with their expectation of entering into a valid business relationship and induced or caused a breach or termination. Nothing more is required….

As to intentional infliction of emotional distress, the court reasoned:

To state a claim for intentional infliction of emotional distress under Illinois law, "a plaintiff must allege facts establishing: (1) that the conduct of the defendant was extreme and outrageous; (2) that the emotional distress suffered by plaintiff was severe; and (3) that defendant's conduct was such that defendant knew that severe emotional distress would be certain or substantially certain to result." In determining whether conduct is extreme and outrageous, courts can consider "whether the plaintiff is particularly susceptible to emotional distress because of some physical or mental condition." Finally, "behavior that might otherwise be considered merely rude, abrasive or inconsiderate may be deemed outrageous if the defendant knows that the plaintiff is particularly susceptible to emotional turmoil." …

[P]laintiffs … point to their allegations that Ancel told Karum he desired to "burn her life down," that he would "fucking ruin [her],"  boasted to third- parties that plaintiffs would be "taken down in an epic way,"  weaponized Karum's autism against her by publicly mocking her in front of other cast and crew members on set and telling her and others that she used her autism "as an excuse for [her] shitty behavior," "poor decision making," and "incompetence," organized a campaign of cyber-bullying against Karum, and told "anyone who would listen that Karum was 'dangerous,'" and that "she baselessly had accused him of sexual assault" which plaintiffs allege is untrue.

Contrary to defendants' argument, plaintiffs allege far more than mere "anger," "humiliation," or "embarrassment," and their allegations are sufficient to state a claim for intentional infliction of emotional distress under Illinois law. See e.g., Summerland v. Constellation Energy Generation, LLC (N.D.Ill. 2025) (denying motion to dismiss an intentional infliction of emotional distress claim where plaintiff alleged defendants "threatened her and interfered with her treatment, despite knowing that she was particularly susceptible to emotional distress, given her known emotional disorders."); Graves v. Man Grp. USA, Inc. (N.D.Ill. 2007) (finding plaintiff's allegations that his supervisors knew he was in and out of the hospital for alcoholism, told his wife and sister that he made death threats against his co-workers (which plaintiff alleged was false), and sent the police to his father's funeral sufficient to withstand a motion to dismiss on plaintiff's IIED claim).

And the court concluded that plaintiffs had adequately alleged civil conspiracy as well.

I found the case interesting for various reasons, the chief being that  if "smears"—including not just outright falsehoods but statements of opinion such as that someone is "unsavory"—"inten[ded] to cause "reputational and economic harm" are actionable, then a lot of cancellation campaigns might be actionable, too. That would be pretty important, given the frequency of such campaigns, whether motivated by business disputes, emotional disputes, political disputes, or other things. See, e.g., Cancelers Beware: Trying to Get Person Fired by Threatening Employer with Cutting Off Your Business Relationship May Be Tortious".

This is in part because the definition of interference with business relations is so unsettled: In some states, the tort applies only to independently criminal or tortious conduct (e.g., threatening customers with violence, defaming the target, etc.). But in other states, apparently including Illinois, the tort can apply also to conduct that is otherwise legal but that the court views as ill-motivated.

And the suggestion that the intentional infliction of emotional distress tort—which is usually defined quite narrowly—can apply in such cases, at least so long as the would-be canceller is aware of the target's "particular[] susceptib[ility]," makes the case seem more relevant still. [UPDATE 8/25/25 11:46 am: I added these three paragraphs after the post went up, thanks in part to a comment from Rossami.]

George J. Spathis (Levelfeld Pearlstein, LLC) represents plaintiffs.