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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.
| Case | Followed | Cited |
|---|---|---|
Wall v. Firelands Radiology, Inc.green2 sentences2024However, 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. | 2 | 2 |
AK Steel Corp. v. Arcelormittal USA, L.L.C.green2 sentences2025However, 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.). | 1 | 2 |
Williams v. Hobbsgreen2 sentences1997However, “ [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). | 1 | 2 |
Total Quality Logistics, L.L.C. v. BBI Logistics, L.LC.green2 sentences2025See 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.). | 1 | 1 |
Professional Investigations, Inc. v. Kingslandgreen2 sentences2024See 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. | 1 | 1 |
Century Business Services, Inc. v. Urbangreen2 sentences2011See, 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. | 1 | 1 |
Briggs v. Butlergreen2 sentences1991See 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 . | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Robert W. Clark, M.D., Inc. v. Mount Carmel Health
green
2 sentences2016Clark, 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. | 1 | 2016–2016 |
Alan v. Andrews, 06 Ma 151 (5-22-2007)
neutral
2 sentences2011No. 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. | 1 | 2011–2011 |
Arthur Murray Dance Studios of Cleveland, Inc. v. Witter
green
2 sentences2008Moreover, 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 | 1 | 2008–2008 |
Raimonde v. Van Vlerah
green
2 sentences1995However, 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. | 1 | 1995–1995 |
Levine v. Beckman
green
2 sentences1991As 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. | 1 | 1991–1991 |