Illinois Appellate Court
Civil Court
Restrictive Covenants
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.)