Beck v. Pickert Medical Group P.C., et al.

Pickert Medical Group, P.C. (Pickert) (defendant) employed approximately two-thirds of the anesthesiologists in northern Nevada. All Pickert anesthesiologists signed employment agreements that contained noncompete clauses barring them, for a period of two years after termination of their employment, from working within 25 miles of Renown Regional Medical Center (Renown) or at any other location where they had performed services two years prior to termination. Some of the noncompetes stated that the employees posed a competitive threat to Pickert because of their specialized skills. The employment agreements also contained confidentiality clauses and clauses prohibiting employees from soliciting Pickert’s patients and customers for two years after termination. Pickert and Renown, which was the region’s only trauma center, entered into a professional-services agreement (PSA) pursuant to which Pickert became Renown’s sole and exclusive provider of anesthesiology services. Renown later terminated the PSA. Pickert anesthesiologists, including Samuel Beck (collectively, employees) (plaintiffs), sued Pickert in Nevada state court, arguing that the noncompetes were void and unenforceable under state law. Concerned that the clauses might also violate federal antitrust law, the United States Department of Justice submitted an interest statement to the trial court.