Sylvan R. Shemitz Designs Inc. v. Brown
A court can deny an employer's request for a temporary injunction to enforce a broad restriction on any employment, not matter how important or menial, because that could significantly harm the former employee's career. In August 2012, Chris Brown's wife gave birth to their first child about two months early, and their child spent one month in neonatal care and experienced continuing health care issues. Chris Brown and his spouse each commuted about 50 to 70 minutes to work. In March 2013, Brown resigned his job for the plaintiff, Sylvan R. Schmitz Designs Inc., and went to work at Acuity. The plaintiff sued Brown and alleged that he breached a 2011 non-compete agreement, which indicated he could not work for one-year for businesses in the United States that receive 25 percent of revenue from developing, manufacturing or selling lighting control systems. The court found that the geographic restraints and one-year duration of the noncompete agreement were reasonable. The restriction on any employment, no matter how important or menial, was not reasonable. Granting the plaintiff's request to enforce such a broad noncompete agreement would significantly harm the defendant's career as an engineer. The plaintiff failed to prove that the defendant currently is involved in research and development in the area of lighting controls or that Acuity intends to pursue the same product lines in which the defendant obtained experience when working for the plaintiff. Currently, the defendant is responsible to design control layouts. He does not appear to be in a position to use his knowledge of the plaintiff's business operations to harm the plaintiff. "Taken as a whole," wrote the court, "the plaintiff has failed to demonstrate how the defendant, whose efforts for Acuity are both of a different character and deal with different products than those on which he worked while with the plaintiff, is in a position to cause irreparable harm." Granting a temporary injunction would cause considerable damage to the defendant. The court denied the plaintiff's motion for a temporary injunction.