Finding a non-compete provision in an employment agreement overbroad on its face and therefore unenforceable, the Supreme Court of Virginia has affirmed dismissal of an employer’s breach of contract claim against a former employee. Home Paramount Pest Control Cos., Inc. v. Shaffer, 2011 Va. LEXIS 222 (Va. Nov. 4, 2011). While acknowledging that it was invalidating a provision that was identical to one it had enforced for the same employer more than 20 years earlier, the Court said the Virginia law on non-competes has evolved since then and overruled conflicting portions of its 1989 opinion.