Mass. Gen. Laws » Part I Title XVI Chapter 112
Massachusetts General Laws

Mass. Gen. Laws ch. 112, § 12X (2026)

Restrictive covenants upon physicians rendered unenforceable

✓ current as of July 2026
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Section 12X. Any contract or agreement which creates or establishes the terms of a partnership, employment, or any other form of professional relationship with a physician registered to practice medicine pursuant to section two, which includes any restriction of the right of such physician to practice medicine in any geographic area for any period of time after the termination of such partnership, employment or professional relationship shall be void and unenforceable with respect to said restriction; provided, however, that nothing herein shall render void or unenforceable the remaining provisions of any such contract or agreement.

Notes of Decisions
Cited in 13 cases, 1994–2019 · leading case: Falmouth Ob-Gyn Assocs., Inc. v. Abisla, 629 N.E.2d 291 (Mass. 1994).
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Falmouth Ob-Gyn Assocs., Inc. v. Abisla, 629 N.E.2d 291 (Mass. 1994). · cites it 10× “754 (1974), on the basis that G. L. c. 112, § 12X, inserted by St. 1977, c.”
Cent. Indiana Podiatry, P.C. v. Krueger, 882 N.E.2d 723 (Ind. 2008). · cites it 2× “6, § 2707 (2005); Mass. Gen. Laws Ann. ch. 112, § 12X (West 2003).”
Murfreesboro Med. Clinic, P.A. v. Udom, 166 S.W.3d 674 (Tenn. 2005). · cites it 2× “6, § 2707 (1993); Mass. Gen. Laws Ann. ch. 112, § 12X (1991).”
Pettingell v. Morrison, Mahoney & Miller, 426 Mass. 253 (Mass. 1997). “The same principle of public policy is expressed in G. L. c. 112, § 12X, concerning physicians, by making void and unenforceable any restriction on the right of a physician to practice in any geographic area after termination of a professional relationship (but leaving the…”
Emerick v. Cardiac Study Ctr., Inc., 286 P.3d 689 (Wash. Ct. App. 2012). “Council on Ethical & Judicial Affairs, Am. Med. Ass’n, Code of Medical Ethics Opinion 9.”
Parikh v. Franklin Med. Ctr., 940 F. Supp. 395 (D. Mass. 1996). · cites it 2× “Parikh and Singla violates both federal and state antitrust laws and Mass.Gen.L. ch. 112, § 12X (Counts III and IV).”
Carr v. Entercom Boston, LLC, 23 Mass. L. Rptr. 138 (Mass. Super. Ct. 2007). “The SJC particularly focused on the phase “any restriction” in G.L.c. 112, §12X, and found a “compensation for competition” clause to be invalid.”
Velazquez v. Eye Health Assocs., LLC, 32 Mass. L. Rptr. 502 (Mass. Super. Ct. 2014). · cites it 6× “This case presents the issue of whether restrictions imposed by an agreement on the form and scope of a physician’s practice are enforceable given the statutory bar of restrictive covenants found in G.L.c. 112, §12X. Plaintiff, Leonardo J. Velazquez, M.”
Am. Express Fin. Advisors, Inc. v. Walker, 9 Mass. L. Rptr. 242 (Mass. Super. Ct. 1998). “Compare G.L.c. 112, §§12X, 74D (1983) (prohibiting non-compete restrictions on the right of doctors and nurses to practice); S.”
Michael Dunn, M.D. v. FastMed Urgent Care, P.C. (Del. Ch. 2019). “19-1172) (amended 2019); Mass. Gen. Laws ch. 112, § 12X (2019); R.”
Pettingell v. Morrison, Mahoney & Miller, 5 Mass. L. Rptr. 215 (Mass. Super. Ct. 1996). · cites it 2× “The Court ruled that the provision, which it referred to as a “compensation-for-competition provision,” was void under G.L.c. 112, §12X. 7 Id. at 182. In making this decision, the Court construed statutory language very similar to that used in Disciplinary Rule 2-108(A), and…”
Ell Pond Med. Assocs., Inc. v. Lipski, 8 Mass. L. Rptr. 138 (Mass. Super. Ct. 1998). “Controlling here, however, is a statute, G.L.c. 112, §12X: Any contract or agreement which .”
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