*According to Minda, this is the most famous commercial case that has ever been decided.
hired defendant as an apprentice baker. Defendant promised not to
compete with plaintiff in the local parish for a period of time in
return for training in the bakery business.
Issue: Did the non-compete agreement constitute a naked restraint of trade?
Holding: No. Court held that promise was necessary in order for the plaintiff to be motivated to hire individuals like defendant.
found that although there is a restraint of trade here, the non-compete
agreement constituted an ancillary/incidental restraint necessary to
accomplish a larger economic/legitimate purpose. Since the underlying
purpose of the agreement was to train defendant, the restraint is said
to be reasonable.
Rule of Law: Reasonableness is to be the test to determine the legality of a restraint of trade.