In Fifield v. Premier Dealer Services, Inc., an Illinois Appellate Court determined that, absent other consideration, at-will employment must continue for two years in order to constitute consideration for the enforcement of competition restrictions. Clients continue to ask how Fifield has been applied by subsequent courts. So far, the results have been mixed. This month, the United States District Court for the Northern District of Illinois rejected Fifield’s bright line test in the case of Bankers Life and Casualty Co. v. Miller, 2015 U.S. Dist. LEXIS 14337 (N.D. Ill. Feb. 6, 2015). In...
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The Evolving Treatment of Fifield v. Premier Dealer Services, Inc.
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