Wednesday, December 25, 2013

Valley Medical Specialists v. Farber case brief

Valley Medical Specialists v. Farber case brief summary
982 P.2d 1277 (1999)

CASE SYNOPSIS
Defendant doctor appealed the decision from the Superior Court in Maricopa County (Arizona), which reversed the trial court's decision that denied plaintiff employer's request for a preliminary injunction and found that plaintiff's restrictive covenant violated public policy, or alternatively, was unenforceable because it was too broad.

CASE FACTS
Defendant doctor, an internist and pulmonologist, entered into an employment agreement with plaintiff employer that contained a restrictive covenant not to compete. After defendant doctor left the practice and began practicing within the area defined by the restrictive covenant, plaintiff sued defendants based on the restrictive covenant not to compete. The trial court denied plaintiff's preliminary injunction request and held that the covenant violated public policy, or alternatively, was unenforceable because it was too broad. The appellate court reversed and held that the covenant was reasonable.

DISCUSSION

  • On review, the court stated that because the doctor-patient relationship was special, it was entitled to unique protection. 
  • Furthermore, based on public policy interests, covenants not to compete between physicians were to be strictly construed for reasonableness. 
  • The court held that the covenant was unenforceable because plaintiff failed to prove that its interests outweighed public policy interests. 
  • The duration and geographic scope were unreasonable. 
  • The trial court's opinion was affirmed, and the appellate court opinion was vacated and remanded.
CONCLUSION
The court vacated and remanded the appellate court decision that reversed the trial court decision that held that plaintiff employer's restrictive covenant with defendant doctor violated public policy. The trial court decision was affirmed because the covenant was unenforceable, for unreasonableness, based on the fact that public policy interests outweighed plaintiff's interests.

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