Cook Sign Company v. Combs

Cook Sign Company (Cook) (plaintiff), acquiring a Minnesota sign business, hired longtime employee Daniel Combs (defendant) under an employment agreement designating North Dakota law, and separately, a month later, had Combs sign a one-year non-competition agreement designating Minnesota law, in exchange for an income guarantee and bonus. After Combs resigned to join a North Dakota competitor, Cook sued in Minnesota and obtained a temporary injunction; Combs appealed, arguing North Dakota law (which does not recognize non-competes) should govern instead.