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Edwards v. Arthur Andersen LLP

Supreme Court of California

81 Cal. Rptr. 3d 282 (Cal. 2008)

Relevant factsFree

Raymond Edwards (plaintiff), a CPA, signed a noncompetition agreement when Arthur Andersen (defendant) hired him, barring him from serving any client he'd worked with at Andersen for 18 months and any client of Andersen's Los Angeles office for 12 months. Edwards sued for intentional interference with prospective economic advantage and unfair competition, relying on California Business and Professions Code § 16600, which voids contracts restraining anyone from engaging in a lawful profession, trade, or business, except for agreements tied to the sale or dissolution of a business entity. Andersen argued "restrained" should be read narrowly to mean only "prohibited" outright, or otherwise limited to unreasonable restraints. The trial court sided with Andersen, and the court of appeal reversed.

IssueFree

Whether employee noncompetition agreements are valid under California law outside the statutory exception for the sale or dissolution of a business.

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