Reliable Fire Equipment Co. v. Arredondo

Illinois Supreme Court
Civil Court
Restrictive Covenants
Citation
Case Number: 
2011 IL 111871
Decision Date: 
Thursday, December 1, 2011
District: 
2d Dist.
Division/County: 
Du Page Co.
Holding: 
Appellate court reversed; circuit court reversed.
Justice: 
FREEMAN
Former employees of fire equipment company, who formed their own company, sought declaratory judgment that noncompetition restrictive covenant they had signed was unenforceable. Three-part test for reasonableness of restrictive covenants includes legitimate business interest of employer as an element. Whether legitimate business interest exists is based on totality of facts and circumstances of individual case, and includes factors of near-permanence of customer relationships, employee's acquisition of confidential information through employment, and time and place restrictions. (KILBRIDE, THOMAS, GARMAN, KARMEIER, BURKE, and THEIS, concurring.)