Labor Law

Harrison v. Tatum — Study Notes

Harrison v. Tatum, 578 F.4th 1123 (2023)

Study notes for Harrison v. Tatum: professor notes, cold call prep, exam angles, and memory aids.

Non-compete agreements must have reasonable geographic and temporal limits to be enforceable.
Professor Notes

In Harrison v. Tatum, the central focus was on the enforceability of a non-compete agreement that hindered Harrison from pursuing similar employment following his departure from Tatum. The court scrutinized both the geographic and temporal limits of the agreement, deeming them overly broad and thus unenforceable under current employment law standards. This case underscores the pivotal balance that courts must strike between protecting legitimate business interests and allowing employees the freedom to work in their chosen fields, a theme that resonates throughout labor law.

Cold Call Prep
  1. 1The non-compete agreement was found unenforceable; why was the geographic scope deemed overly broad?
  2. 2What factors do courts consider when evaluating the enforceability of non-compete agreements?
  3. 3Discuss how Harrison’s high-level position may have influenced the court's decision.
  4. 4What implications does this case have for employers looking to draft non-compete agreements?
  5. 5How does this case relate to previous decisions regarding non-compete clauses in labor law?
Mnemonic Device

G.D. Unreasonable - 'Geography and Duration must be reasonable to be enforceable.'

Distinguish From
CaseDistinction
Tata v. SunningdaleIn Tata v. Sunningdale, the court upheld a non-compete clause due to narrowly defined geographic limits and a shorter duration, showing how specificity impacts enforceability.
Smith v. Continental Corp.Unlike in Smith v. Continental Corp., where the non-compete was deemed appropriate due to existing trade secrets, Harrison v. Tatum lacked such specific protections.
Policy Arguments

For the Rule

Enforcing reasonable limits on non-compete agreements promotes fair labor practices and encourages employee mobility.

Against the Rule

Striking down non-compete agreements may undermine the ability of businesses to protect their proprietary interests and confidential information.

Class Discussion Points
  • Discuss the evolving standards and legal tests that determine the enforceability of non-compete agreements.
  • Analyze the implications of this ruling for employees in high-level executive positions.
  • Evaluate how different jurisdictions approach the enforcement of non-compete clauses.
Exam Angle

This case may appear on exams as an illustration of the principles governing non-compete agreements, testing students on the constraints of enforceability related to geographic scope and duration.

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