Illinois Appellate Court Applies Reliable Fire Retroactively to Reverse and Remand Hair Salon Restrictive Covenant Case

In Reliable Fire Equipment Company v. Arrendondo [pdf], discussed here, the Supreme Court of Illinois dramatically altered how protectable legitimate business interests in noncompetition agreements were to be reviewed under Illinois law, clarifying what it felt were decades of misapplication. On February 3, 2012, the first decision was issued applying Reliable Fire in a retroactive fashion, resulting in an Illinois appellate court reversing and remanding a lower court decision denying enforcement of a noncompetition agreement.