Connecticut Decision Highlights Importance of Identifying a Protectable Business Interest in Restrictive Covenants

A Connecticut state court recently found non-compete/non-solicitation agreements unreasonable and therefore unenforceable because the agreements did not protect any legitimate business interest. Creative Dimensions, Inc. v. Laberge is an unusual case in that the court found the agreements were reasonable in terms of their geographical and temporal restrictions, but nevertheless invalidated the agreements because they were inherently unfair to the employee-defendants. In reaching this conclusion, the court balanced the employee-defendants’ inability to work for 18 months against the employer’s failure to identify a protectable interest justifying the 18-month restriction.