Antitrust and Consumer Protection

Competition: VOLUME 34, NUMBER 1, FALL 2024

TRENDS IN NON-COMPETE LITIGATION AND ENFORCEMENT

By Bonnie Laua1, Margaret Webbb2, Anissa Chitourc3

INTRODUCTION

Prosecution of no-poach agreements has been a recent focus for the Department of Justice (DOJ) Antitrust Division. But in the past two years, DOJ has seen several losses, including a judgment of acquittal from the bench in United States v. Patel,4 a jury acquittal in United States v. DaVita,5 and a voluntary dismissal by the Division in November 2023.6 Despite DOJ’s recent string of losses in its criminal prosecution of no-poach agreements, federal and state enforcement agencies have continued to closely scrutinize employment agreements through new legislation and rulemaking intended to crack down on a wide range of "non- compete" clauses. Private plaintiffs also have been aggressively exploring novel avenues of potential liability.

California has prohibited such provisions in employment agreements for years. California recently expanded its legislation, and other states have enacted similar legislation. The California Department of Justice’s Antitrust Division has signaled a renewed interest in criminal enforcement of its antitrust statute, alongside heavy scrutiny of non-compete agreements.

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