Raimonde test (Ohio) · Go Syfert
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Raimonde test in Ohio

9 Ohio opinions name it 1 courts 1991–2025 3 in the last five years

The cases below were cited by Ohio 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 (7)

CaseFollowedCited
Wall v. Firelands Radiology, Inc.green
ohioctapp · 1995 · cited in 2 Ohio opinions naming this issue, 2016–2024
2 sentences

2024However, the Raimonde test requires more than just some hardship . . ." AK Steel Corp., 2016-Ohio-3285 at ¶ 19 , quoting Wall v. Firelands Radiology, Inc., 106 Ohio App.3d 313, 333 (6th Dist. 1995), Robert W.

2024However, the Raimonde test requires more than just some hardship . . ." AK Steel Corp., 2016-Ohio-3285 at ¶ 19 , quoting Wall v. Firelands Radiology, Inc., 106 Ohio App.3d 313, 333 (6th Dist. 1995), Robert W.

22
AK Steel Corp. v. Arcelormittal USA, L.L.C.green
ohioctapp · 2016 · cited in 2 Ohio opinions naming this issue, 2024–2025
2 sentences

2025However, the Raimonde test requires more than just some hardship." AK Steel Corp. v. Arcelormittal USA, L.L.C., 2016-Ohio-3285, ¶ 19 (12th Dist.).

2025However, the Raimonde test requires more than just some hardship." AK Steel Corp. v. Arcelormittal USA, L.L.C., 2016-Ohio-3285, ¶ 19 (12th Dist.).

12
Williams v. Hobbsgreen
ohioctapp · 1983 · cited in 2 Ohio opinions naming this issue, 1991–1997
2 sentences

1997However, “ [t]he Raimonde test requires more than just some hardship.” Williams v. Hobbs (1983), 9 Ohio App.3d 331, 336 , 9 OBR 599, 604, 460 N.E.2d 287, 293 (Moyer, J., concurring in part and dissenting in part).

1997However, “ [t]he Raimonde test requires more than just some hardship.” Williams v. Hobbs (1983), 9 Ohio App.3d 331, 336 , 9 OBR 599, 604, 460 N.E.2d 287, 293 (Moyer, J., concurring in part and dissenting in part).

12
Total Quality Logistics, L.L.C. v. BBI Logistics, L.LC.green
ohioctapp · 2024 · cited in 1 Ohio opinions naming this issue, 2025–2025
2 sentences

2025See BBI Logistics, 2024-Ohio-2597, at ¶ 39 (12th Dist.). {¶ 34} While the public interest is served by robust competition between companies, a company such as Reliant still has an interest in preventing unfair competition.

2025BBI Logistics at ¶ 31 (12th Dist.).

11
Professional Investigations, Inc. v. Kingslandgreen
ohioctapp · 1990 · cited in 1 Ohio opinions naming this issue, 2024–2024
2 sentences

2024See Professional Investigations, 69 Ohio App.3d at 760 , 591 N.E.2d 1265 (“To bring [plaintiff’s] non- competition clause into compliance with the rule of reasonableness, the trial court could not easily modify existing provisions but might be required to rewrite the entire covenant. * * * We have found no case which states that a trial court must totally rewrite a provision in order to carry out its discretionary powers.”); S & S, Inc. v. Kuret, 8th Dist.

2024See Professional Investigations, 69 Ohio App.3d at 760 , 591 N.E.2d 1265 (“To bring [plaintiff’s] non- competition clause into compliance with the rule of reasonableness, the trial court could not easily modify existing provisions but might be required to rewrite the entire covenant. * * * We have found no case which states that a trial court must totally rewrite a provision in order to carry out its discretionary powers.”); S & S, Inc. v. Kuret, 8th Dist.

11
Century Business Services, Inc. v. Urbangreen
ohioctapp · 2008 · cited in 1 Ohio opinions naming this issue, 2011–2011
2 sentences

2011See, e.g., Century Business Servs., Inc. v. Urban, 179 Ohio App.3d 111 , 2008-Ohio-5744 , 900 N.E.2d 1048, at ¶25 (applying - 20 - Raimonde to non-compete agreement entered into simultaneously with the sale of a business). {¶95} The burden is on the former employer to prove the restraint is reasonable and the agreement is valid.

2011See, e.g., Century Business Servs., Inc. v. Urban, 179 Ohio App.3d 111 , 2008-Ohio-5744 , 900 N.E.2d 1048, at ¶25 (applying - 20 - Raimonde to non-compete agreement entered into simultaneously with the sale of a business). {¶95} The burden is on the former employer to prove the restraint is reasonable and the agreement is valid.

11
Briggs v. Butlergreen
· 1942 · cited in 1 Ohio opinions naming this issue, 1991–1991
2 sentences

1991See Briggs, supra, 140 Ohio St. at 507 , 24 O.O. at 526 , 45 N.E.2d at 761 .

1991See Briggs, supra, 140 Ohio St. at 507 , 24 O.O. at 526 , 45 N.E.2d at 761 .

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (5)

CaseCitedYears
Robert W. Clark, M.D., Inc. v. Mount Carmel Health green
ohioctapp · 1997
2 sentences

2016Clark, M.D., Inc. 124 Ohio App.3d at 318 . {¶ 20} The evidence in this case demonstrated that Howell would be prevented from maintaining employment in the steel industry for a period of one year.

2016Clark, M.D., Inc. 124 Ohio App.3d at 318 . {¶ 20} The evidence in this case demonstrated that Howell would be prevented from maintaining employment in the steel industry for a period of one year.

12016–2016
Alan v. Andrews, 06 Ma 151 (5-22-2007) neutral
ohioctapp · 2007
2 sentences

2011No. 06 MA 151, 2007-Ohio-2608, at ¶40 . {¶94} Although the agreement between Miller and J&B is not the typical employer-employee non-competition agreement as it involves a post-employment contract, the Raimonde factors still apply.

2011No. 06 MA 151, 2007-Ohio-2608, at ¶40 . {¶94} Although the agreement between Miller and J&B is not the typical employer-employee non-competition agreement as it involves a post-employment contract, the Raimonde factors still apply.

12011–2011
Arthur Murray Dance Studios of Cleveland, Inc. v. Witter green
ohctcomplcuyaho · 1952
2 sentences

2008Moreover, an employee ordinarily is not on the same plane with the seller of an established business.” Id. at 60-61 . *120 {¶ 25} Thus, restrictive covenants entered into simultaneously with the sale of a business should be distinguished from such covenants that are entered into by an employer and employee, and should be enforced if they are reasonable under the Raimonde test. {¶ 26} With this in mind, before we address Urban’s arguments relating to the Raimonde factors, we must first consider a theme that he raised throughout trial, and in his brief to this court, because it affects every oth

2008Moreover, an employee ordinarily is not on the same plane with the seller of an established business.” Id. at 60-61 . *120 {¶ 25} Thus, restrictive covenants entered into simultaneously with the sale of a business should be distinguished from such covenants that are entered into by an employer and employee, and should be enforced if they are reasonable under the Raimonde test. {¶ 26} With this in mind, before we address Urban’s arguments relating to the Raimonde factors, we must first consider a theme that he raised throughout trial, and in his brief to this court, because it affects every oth

12008–2008
Raimonde v. Van Vlerah green
ohio · 1975
2 sentences

1995However, the Raimonde test [Raimonde v. Van Vlerah (1975), 42 Ohio St.2d 21 , 71 O.O.2d 12 , 325 N.E.2d 544 ] requires more than just some hardship.

1995However, the Raimonde test [Raimonde v. Van Vlerah (1975), 42 Ohio St.2d 21 , 71 O.O.2d 12 , 325 N.E.2d 544 ] requires more than just some hardship.

11995–1995
Levine v. Beckman green
ohioctapp · 1988
2 sentences

1991As this court stated in Levine v. Beckman (1988), 48 Ohio App.3d 24 , 548 N.E.2d 267 , in addition to the burden on plaintiff of producing clear and convincing evidence as to each element in the Raimonde test, it is incumbent that the plaintiff prove irreparable injury or the existence of an actual threat of such injury.

1991As this court stated in Levine v. Beckman (1988), 48 Ohio App.3d 24 , 548 N.E.2d 267 , in addition to the burden on plaintiff of producing clear and convincing evidence as to each element in the Raimonde test, it is incumbent that the plaintiff prove irreparable injury or the existence of an actual threat of such injury.

11991–1991

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