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Home > State Law Articles > Illinois > Restrictive Covenants (IL) > Illinois Appellate Court Finds Insufficient Consideration Where Employer Relied on Under Two Years Employment in Support of Noncompetition and Nonsolicitation Agreements

Illinois Appellate Court Finds Insufficient Consideration Where Employer Relied on Under Two Years Employment in Support of Noncompetition and Nonsolicitation Agreements

Filed Under: Restrictive Covenants (IL)

On June 24, 2013, the Illinois Appellate Court for the First District (encompassing Cook County and Chicago) decided Fifield v. Premier Dealer Services, Inc., Case No. 1-12-0327 (June 24, 2013). The court found that Premier Dealer Services’ (Premier) offer of at-will employment at the onset of the plaintiff’s employment constituted insufficient consideration to support nonsolicitation and noncompetition provisions contained in his employment contract, but it would have constituted adequate consideration if his employment had continued for two years.