Wood v. May

Wood (plaintiff), a master horseshoer, trained May (defendant) as an apprentice under a contract with a noncompete clause barring May from horseshoeing within 100 miles of Wood's business for five years. After working for Wood for almost two years, May quit and opened his own horseshoeing business just five miles away, in an area with roughly 3,000 horses and eight professional horseshoers. Wood sued to enforce the noncompete; the trial court found the 100-mile radius unreasonable and, believing the contract indivisible, dismissed the suit entirely rather than modifying the unreasonable term.

Whether noncompetition covenants are enforceable only if their restrictions are not greater than are reasonably necessary to protect the employer's business or goodwill.