Postemployment Restrictive Covenants: Client Base Protection in Washington—Perry v. Moran, 109 Wash. 2d 691, 748 P.2d 224 (1987), modified, 111 Wash. 2d 885, 766 P.2d 1096, cert. denied, 109 S. Ct. 3228 (1989)

Authors

Susan E. Corisis

Abstract

Most jurisdictions enforce postemployment noncompetition covenants that reasonably prevent an employee from using his or her relationship with the employer's clients to take the clients. In Perry v. Moran, the Washington Supreme Court enforced an employment agreement that prevented the employee from taking her employer's clients, regardless of whether she had personal contact with each of the clients or whether the clients had left the employer's services for reasons other than to follow the employee. This note concludes that a postemployment noncompetition covenant is not reasonable if it prevents an employee from serving an employer's clients with whom the employee had no significant personal contact or clients who left the employer's services for reasons other than to follow the employee.

First Page

209

Recommended Citation

Susan E. Corisis, Note, Postemployment Restrictive Covenants: Client Base Protection in Washington—Perry v. Moran, 109 Wash. 2d 691, 748 P.2d 224 (1987), modified, 111 Wash. 2d 885, 766 P.2d 1096, cert. denied, 109 S. Ct. 3228 (1989), 65 Wash. L. Rev. 209 (1990).
Available at: https://digitalcommons.law.uw.edu/wlr/vol65/iss1/8