Fifield v. Premier Dealer Services, Inc.

Illinois Appellate Court
Civil Court
Citation
Case Number: 
2013 IL App (1st) 120327
Decision Date: 
June 24, 2013
District: 
1st Dist.
Division/County: 
Cook Co.,1st Div.
Justice: 
CUNNINGHAM
Holding: 
Affirmed.
At least two years of continued employment is required to constitute adequate consideration in support of a restrictive covenant, whether employee resigns or is terminated. Thus, employee who resigned after three months' employment is not bound by non-solicitation and non-interference provisions in employment contract, and first-year provision in contract does not affect application of requisite two-year standard for adequate consideration. (HOFFMAN and DELORT, concurring.)