Posts tagged Fifield.
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Is Fifield’s holding holding?
Categories: Non-Compete Agreements, Non-Solicit Agreements
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A couple years ago, the Illinois First District Appellate Court decided the case of Fifield v. Premier Dealer Services, 2013 IL App. 120327.  There, the Court held that, absent other consideration, two years of employment are required to constitute adequate consideration for a restrictive covenant, regardless of whether the covenant was signed at the outset of employment or after, and regardless of whether the employee quit or was fired.  Since then, some Judges in the United States District Court for the Northern District of Illinois have applied Fifield, and others have declined ...

Blogs
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Another Illinois Appellate Decision Applies Fifield, But A Dissent Suggests That The Issue Of What Constitutes Adequate Consideration For A Restrictive Covenant In Illinois Remains Open For Judicial Discussion
Categories: Non-Compete Agreements
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Readers of this blog know that long settled understandings regarding what constitutes adequate consideration for a restrictive covenant in Illinois were turned upside down when the First District Appellate Court in Illinois held in Fifield v. Premier Dealer Services, 2013 IL App. (1st) 120327  that, absent other consideration, two years of employment are required for a restrictive covenant to be supported by adequate consideration, regardless of whether the covenant was signed at the outset of employment or after, and regardless of whether the employee quit or was fired.

The ...

Blogs
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The First Illinois Appellate Court Decision To Address Fifield’s “Two Years Of Employment/Consideration Rule” Strictly Adheres To It
Categories: Non-Compete Agreements
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Readers of this blog know that in the summer of 2013, long held beliefs about the required consideration for a restrictive covenant under Illinois law were thrown a curve when the Illinois Appellate Court for the First District (i.e., Cook County) held in Fifield v. Premier Dealer Services, Inc., 2013 IL App (1st) 120327, that, absent other consideration, two years of employment is required for a restrictive covenant to be deemed supported by adequate consideration—even where the employee signed the restrictive covenant as a condition to his employment offer and even where the ...

Blogs
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Federal District Judges In Chicago Are Now Split Over Whether To Follow The Illinois Appellate Court's Landmark Fifield Decision
Categories: Non-Compete Agreements
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Federal district judges in Chicago are now split over whether to follow the Illinois appellate court's landmark non-compete decision, Fifield v. Premier Dealer Services, Inc., 373 Ill. Dec. 379, 993 N.E. 2d 938 (Ill. App. 1st Dist. 2013).
Blogs
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Chief Federal District Judge In Chicago Declines To Follow Illinois Appellate Court Holding That, Absent Other Consideration, Two Years Of Employment Is Required Consideration For A Restrictive Covenant
Categories: Non-Compete Agreements
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Judge Ruben Castillo, the Chief Judge for the United States District Court for the Northern District of Illinois, recently declined to follow a widely publicized Illinois Appellate Court decision in which the Appellate Court held that, absent other consideration, two years of employment is required consideration for a restrictive covenant in Illinois.
Blogs
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Since Fifield Is Not Going Away Any Time Soon, Illinois Employers Should Consider Revising the Consideration Provided for Restrictive Covenants
Categories: Non-Compete Agreements
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A recent decision by one district of the Illinois Court of Appeals (Fifield v. Premier Dealer Services) significantly altered long-settled understandings regarding the consideration required for an enforceable restrictive covenant in Illinois. In light of that decision, Illinois employers hoping to enforce restrictive covenants within two years after the signing date should be prepared to distinguish Fifield factually or legally. Employers that are concerned about their ability to do so, or that want to err on the side of caution, should act now to address the implications of Fifield.
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Illinois Supreme Court Decides Not To Review Lower Court Ruling That, Absent Other Consideration, Two Years Of Employment Is Required Consideration For A Restrictive Covenant
Categories: Non-Compete Agreements
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The Illinois Supreme Court recently announced that it was not going to review an Illinois Appellate Court decision, Fifield v. Premier Dealer Services, Inc., which held that, absent other consideration, two years of employment is required for a restrictive covenant to be deemed supported by adequate consideration - even where the employee signed the restrictive covenant as a condition to his employment offer - and even where the employee voluntarily resigned.
Blogs
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Illinois Court Holds That, Absent Other Consideration, Two Years Of Employment Is Required Consideration For A Restrictive Covenant
Categories: Non-Compete Agreements
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In Fifield v. Premier Dealer Services, Inc., an Illinois Appellate Court recently held that, absent other consideration, two years of employment is required for a restrictive covenant to be deemed supported by adequate consideration - even where the employee signed the restrictive covenant as a condition to his employment offer - and even where the employee voluntarily resigned.

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