non-compete clause (Missouri) · Go Syfert
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non-compete clause in Missouri

11 Missouri opinions name it 2 courts 1988–2021 1 in the last five years

The cases below were cited by Missouri courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (12)

CaseFollowedCited
Superior Gearbox Co. v. Edwardsgreen
moctapp · 1993 · cited in 2 Missouri opinions naming this issue, 1996–2012
2 sentences

2012See Osage Glass, Inc. v. Donovan, 693 S.W.2d 71, 74 (Mo. banc 1985) (enforcing a non-compete clause but refusing to enforce it to the extent it was unreasonable); Orchard Container Corp. v. Orchard, 601 S.W.2d 299, 304 (Mo.App.1980); see also Superior Gearbox Co., 869 S.W.2d at 249 . 6 The provisions of the customer non-solicitation clauses that prohibit Mr. Kennebrew and Mr. Morgan from soliciting any existing Whelan customer or any prospective customer from the last 12 months, throughout the nation, are unreasonably broad under the circumstances.

2012See Osage Glass, Inc. v. Donovan, 693 S.W.2d 71, 74 (Mo. banc 1985) (enforcing a non-compete clause but refusing to enforce it to the extent it was unreasonable); Orchard Container Corp. v. Orchard, 601 S.W.2d 299, 304 (Mo.App.1980); see also Superior Gearbox Co., 869 S.W.2d at 249 . 6 The provisions of the customer non-solicitation clauses that prohibit Mr. Kennebrew and Mr. Morgan from soliciting any existing Whelan customer or any prospective customer from the last 12 months, throughout the nation, are unreasonably broad under the circumstances.

12
Binder v. Thorne-Bindergreen
moctapp · 2006 · cited in 1 Missouri opinions naming this issue, 2021–2021
1 sentence

2021See Binder v. Thorne-Binder, 186 S.W.3d 864, 867 (Mo. App. W.D. 2006) (noting Rule 61.01 does not require court to make written findings of prejudice).

11
Willman v. Behelergreen
mo · 1973 · cited in 1 Missouri opinions naming this issue, 2021–2021
1 sentence

2021See Willman v. Beheler, 499 S.W.2d 770, 778 (Mo. 1973), abrogated on other grounds by State ex rel.

11
Hawk Isolutions Group, Inc. v. Morrisgreen
moctapp · 2009 · cited in 1 Missouri opinions naming this issue, 2021–2021
1 sentence

2021Point denied. 7 The general rule is that an amended pleading “abandons any prior pleadings not referred to or incorporated into the new pleading.” Hawk Isolutions Group, Inc. v. Morris, 288 S.W.3d 758, 762 (Mo. App. E.D. 2009).

11
Simpkins v. Ryder Freight System, Inc.green
moctapp · 1993 · cited in 1 Missouri opinions naming this issue, 2021–2021
1 sentence

2021See Simpkins v. Ryder Freight Sys., Inc., 855 S.W.2d 416, 20-21 (Mo. App. W.D. 1993).

11
Orchard Container Corp. v. Orchardgreen
moctapp · 1980 · cited in 1 Missouri opinions naming this issue, 2012–2012
2 sentences

2012See Osage Glass, Inc. v. Donovan, 693 S.W.2d 71, 74 (Mo. banc 1985) (enforcing a non-compete clause but refusing to enforce it to the extent it was unreasonable); Orchard Container Corp. v. Orchard, 601 S.W.2d 299, 304 (Mo.App.1980); see also Superior Gearbox Co., 869 S.W.2d at 249 . 6 The provisions of the customer non-solicitation clauses that prohibit Mr. Kennebrew and Mr. Morgan from soliciting any existing Whelan customer or any prospective customer from the last 12 months, throughout the nation, are unreasonably broad under the circumstances.

2012See Osage Glass, Inc. v. Donovan, 693 S.W.2d 71, 74 (Mo. banc 1985) (enforcing a non-compete clause but refusing to enforce it to the extent it was unreasonable); Orchard Container Corp. v. Orchard, 601 S.W.2d 299, 304 (Mo.App.1980); see also Superior Gearbox Co., 869 S.W.2d at 249 . 6 The provisions of the customer non-solicitation clauses that prohibit Mr. Kennebrew and Mr. Morgan from soliciting any existing Whelan customer or any prospective customer from the last 12 months, throughout the nation, are unreasonably broad under the circumstances.

11
Osage Glass, Inc. v. Donovangreen
mo · 1985 · cited in 1 Missouri opinions naming this issue, 2012–2012
2 sentences

2012See Osage Glass, Inc. v. Donovan, 693 S.W.2d 71, 74 (Mo. banc 1985) (enforcing a non-compete clause but refusing to enforce it to the extent it was unreasonable); Orchard Container Corp. v. Orchard, 601 S.W.2d 299, 304 (Mo.App.1980); see also Superior Gearbox Co., 869 S.W.2d at 249 . 6 The provisions of the customer non-solicitation clauses that prohibit Mr. Kennebrew and Mr. Morgan from soliciting any existing Whelan customer or any prospective customer from the last 12 months, throughout the nation, are unreasonably broad under the circumstances.

2012See Osage Glass, Inc. v. Donovan, 693 S.W.2d 71, 74 (Mo. banc 1985) (enforcing a non-compete clause but refusing to enforce it to the extent it was unreasonable); Orchard Container Corp. v. Orchard, 601 S.W.2d 299, 304 (Mo.App.1980); see also Superior Gearbox Co., 869 S.W.2d at 249 . 6 The provisions of the customer non-solicitation clauses that prohibit Mr. Kennebrew and Mr. Morgan from soliciting any existing Whelan customer or any prospective customer from the last 12 months, throughout the nation, are unreasonably broad under the circumstances.

11
National Rejectors, Inc. v. Triemangreen
mo · 1966 · cited in 1 Missouri opinions naming this issue, 2009–2009
1 sentence

2009A “trade secret” can be “ ‘any formula, pattern, device or compilation of information which is used in one’s business, and which gives him an opportunity to obtain an advantage over competitors who do not know or use it.’ ” Kessler-Heasley, 90 S.W.3d at 188 (quoting National Rejectors, Inc. v. Trieman, 409 S.W.2d 1, 18-19 (Mo. banc 1966)). 2 Some factors to be considered in determining whether certain information is a trade secret are: “(1) the extent to which the information is known outside of his business; (2) the extent to which it is known by employees and others involved in his business;

11
Cohn v. Jefferson Savings & Loan Associationgreen
mo · 1961 · cited in 1 Missouri opinions naming this issue, 2003–2003
1 sentence

2003See Cohn v. Jefferson Sav. & Loan Ass’n, 349 S.W.2d 854, 858 (Mo.1961); RESTATEMENT (SECOND) OF AGENCY § 393 (1958) (“Unless otherwise agreed, an agent is subject to a duty not to compete with the principal concerning the subject matter of his agency.”).

11
Empire Gas Corp. v. Grahamgreen
moctapp · 1983 · cited in 1 Missouri opinions naming this issue, 2002–2002
1 sentence

2002See id.

11
Washington County Memorial Hospital v. Sidebottomgreen
moctapp · 1999 · cited in 1 Missouri opinions naming this issue, 2002–2002
1 sentence

2002See Sidebottom, 7 S.W.3d at 546 .

11
Starkings Court Reporting Services, Inc. v. Collinsgreen
ncctapp · 1984 · cited in 1 Missouri opinions naming this issue, 1997–1997
2 sentences

1997Id, In Starkings Court Reporting Serv. v. Collins, 67 N.C.App. 540 , 313 S.E.2d 614, 616 (1984), the court held that covenants not to compete are applicable to the independent contractor relationship.

1997Id, In Starkings Court Reporting Serv. v. Collins, 67 N.C.App. 540 , 313 S.E.2d 614, 616 (1984), the court held that covenants not to compete are applicable to the independent contractor relationship.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Missouri. Read the followed side critically anyway.

Also cited on this issue (12)

CaseCitedYears
Mid-States Paint & Chemical Co. v. Herr green
moctapp · 1988
1 sentence

2021Co. v. Herr, 746 S.W.2d 613 (Mo. App. E.D. 1988) (finding radius of 125 miles reasonable where majority of industrial coatings company’s customers were within such radius, trial court had noted even 350-mile radius would have been reasonable).

12021–2021
Furniture Manufacturing Corp. v. Joseph green
moctapp · 1995
1 sentence

2021Corp. v. Joseph, 900 S.W.2d 642 (Mo. App. W.D. 1995) (plaintiff had sought temporary restraining order upon learning of former employee’s competition; appellate court remanded for consideration of whether injunctive relief was appropriate, noting extension of term from date of decree “would not be inequitable” if trial court determined relief is warranted). 22 We also note the non-compete clause contains a severance clause, stating in part, “It is the intention of the parties to restrict [Huff]’s activities only to the extent necessary for the protection of [Carmed 45’s members’] legitimate bu

12021–2021
Grand Bissell Towers, Inc. v. Joan Gagnon Enterprises, Inc. green
moctapp · 1983
2 sentences

2021To the extent that any [provision of the non-compete clause] shall be determined to be invalid or unenforceable . . ., [it] shall be automatically amended [to] grant [Carmed 45’s members] the maximum protection and restrictions on [Huff]’s activities permitted by applicable law in such circumstances.” 33 occur.” Grand Bissell, 657 S.W.2d at 379 n.3.

2021To the extent that any [provision of the non-compete clause] shall be determined to be invalid or unenforceable . . ., [it] shall be automatically amended [to] grant [Carmed 45’s members] the maximum protection and restrictions on [Huff]’s activities permitted by applicable law in such circumstances.” 33 occur.” Grand Bissell, 657 S.W.2d at 379 n.3.

12021–2021
Whelan Security Co. v. Kennebrew green
mo · 2012
2 sentences

2021Whelan, 379 S.W.3d at 846 -47 (citing cases).

2021Whelan, 379 S.W.3d at 846 -47 (citing cases; noting “[c]onsiderable precedent in Missouri supports the reasonableness of 19 Huff bases much of his argument on another provision in the non-compete clause, which contained a prohibition on PDR work “within a 50 [-] mile radius of the geographic area in which any affiliate of the Partnership or of the Class A Partners provided such services during the time that [Huff] held his Percentage Interest.” However, the trial court did not rely on this provision, but found Huff had violated the above- quoted clause describing a 50-mile radius from Carmed 4

12021–2021
Champion Sports Center, Inc. v. Peters green
moctapp · 1989
1 sentence

2013Id. at 369 .

12013–2013
Kessler-Heasley Artificial Limb Co. v. Kenney green
moctapp · 2002
1 sentence

2009A “trade secret” can be “ ‘any formula, pattern, device or compilation of information which is used in one’s business, and which gives him an opportunity to obtain an advantage over competitors who do not know or use it.’ ” Kessler-Heasley, 90 S.W.3d at 188 (quoting National Rejectors, Inc. v. Trieman, 409 S.W.2d 1, 18-19 (Mo. banc 1966)). 2 Some factors to be considered in determining whether certain information is a trade secret are: “(1) the extent to which the information is known outside of his business; (2) the extent to which it is known by employees and others involved in his business;

12009–2009
Continental Research Corp. v. Scholz green
moctapp · 1980
1 sentence

2009A “trade secret” can be “ ‘any formula, pattern, device or compilation of information which is used in one’s business, and which gives him an opportunity to obtain an advantage over competitors who do not know or use it.’ ” Kessler-Heasley, 90 S.W.3d at 188 (quoting National Rejectors, Inc. v. Trieman, 409 S.W.2d 1, 18-19 (Mo. banc 1966)). 2 Some factors to be considered in determining whether certain information is a trade secret are: “(1) the extent to which the information is known outside of his business; (2) the extent to which it is known by employees and others involved in his business;

12009–2009
Healthcare Services of the Ozarks, Inc. v. Copeland green
mo · 2006
1 sentence

2009A “trade secret” can be “ ‘any formula, pattern, device or compilation of information which is used in one’s business, and which gives him an opportunity to obtain an advantage over competitors who do not know or use it.’ ” Kessler-Heasley, 90 S.W.3d at 188 (quoting National Rejectors, Inc. v. Trieman, 409 S.W.2d 1, 18-19 (Mo. banc 1966)). 2 Some factors to be considered in determining whether certain information is a trade secret are: “(1) the extent to which the information is known outside of his business; (2) the extent to which it is known by employees and others involved in his business;

12009–2009
Hendricks v. Northcutt green
moctapp · 1991
1 sentence

2004Furthermore, in Hendriclcs the plaintiffs did absolutely nothing to invoke their rights for several years, id. at 691 , whereas here, appellants sued on the Contract to prevent the sale to the Fuemmelers within a short time after discovering, on their own and with no assistance from Whitlock, the identity of the buyers, and realizing that they were business competitors.

12004–2004
AEE-EMF, INC. v. Passmore green
moctapp · 1995
1 sentence

1997Id.

11997–1997
Keller v. Missouri Baptist Hospital of Sullivan green
moctapp · 1990
1 sentence

1995Keller, 800 S.W.2d at 38 .

11995–1995
USA Chem, Inc. v. Lewis green
moctapp · 1977
1 sentence

1988Rejecting the argument, the appellate court explained that mutuality of obligation is often confused with consideration; that consideration is essential but mutuality of obligation is not, unless want of mutuality would leave one party without a valid or available consideration for his promise. 557 S.W.2d at 24 .

11988–1988

Where else courts name it

PA 23 (2001–2025) FL 15 (1982–2021) OH 14 (2001–2024) GA 13 (1991–2025) MO 11 (1988–2021) LA 11 (1988–2019) VA 10 (2005–2026) TX 9 (2001–2024) NV 7 (2015–2016) NC 6 (2002–2019) NY 6 (2001–2025) IN 5 (2000–2010) NJ 5 (2003–2020) UT 3 (2016–2024) DE 3 (2017–2023) IA 3 (2018–2026) TN 3 (2001–2009) CT 2 (1998–2001) NM 2 (2014–2015) WI 2 (2009–2022) KY 2 (2009–2022) HI 2 (2022–2022) AK 2 (1992–2012) ID 2 (2008–2022) MI 2 (2018–2018)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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