Prairie Rheumatology Associates, S.C. v. Francis

Court entered preliminary injunction enjoining clinic's former employee physician from treating clinic's current patiens but allowing her to treat patients she had prior to joining clinic and potential future patients. Physician left clinic practice 19 months after her employment began, which is 5 months less than the general 2-year rule of thumb that supports adequate consideration for postemployment restrictive covenant. Physician received little or no additional benefit from clinic in exchange for her agreement not to compete. Thus, restrictive covenant is unenforceable and clinic cannot show likelihood of prevailing on the merits.(CARTER and O'BRIEN, concurring.)