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Bankers Life & Casualty Co. v. American Senior Benefits LLC
Illinois Appellate Court
2017 IL App (1st) 160687, 83 N.E.3d 1085 (2017)
Gregory Gelineau (defendant) worked for American Senior Benefits LLC (defendant). Gelineau was subject to a noncompetition provision from his previous employer, Bankers Life and Casualty Company (Bankers Life) (plaintiff) for two years following the end of his employment. Bankers Life and American Senior Benefits were competitors in the insurance industry. The noncompetition provision included a prohibition on Gelineau attempting to induce Bankers Life employees to leave the company. While working for American Senior Benefits and still subject to the Bankers Life noncompetition provision, Gelineau sent three LinkedIn requests to connect with three Bankers Life employees. Gelineau did not send direct messages to the employees. The requests were in the form of generic emails generated by LinkedIn using Gelineau’s contact list. The emails were simply a request to form a professional networking connection and made no mention of Bankers Life, American Senior Benefits, or employment of any kind. Bankers Life filed a claim for breach of contract against Gelineau, American Senior Benefits, and five other defendants in circuit court. The circuit court granted summary judgment in favor of Gelineau. Bankers Life appealed to the Illinois Appellate Court.
Rule of Law
Holding and Reasoning (Simon, J.)
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