Coady v. Harpo, Inc.

Elizabeth Coady (plaintiff) worked for Harpo, Inc. (defendant) in various positions, including as a producer for The Oprah Winfrey Show. In March 1995, Coady signed a Business Ethics, Objectivity, and Confidentiality Policy (confidentiality agreement), which provided, among other things, that Coady must keep as confidential and never disclose any statements about Winfrey, Harpo, or any of Winfrey’s and Harpo’s confidential information. The agreement defined confidential information to include information about Winfrey’s business and personal life and Harpo’s business affairs. The confidentiality agreement conditioned Coady’s employment with Harpo on her compliance with the confidentiality requirements. Coady resigned from her position with Harpo in March 1998. Coady alleged that she had been constructively terminated because Harpo had taken actions intended to force Coady out of her job. The following month, Harpo wrote Coady a letter reminding her of her obligations under the confidentiality agreement. Harpo stated that it intended to enforce the agreement and ensure Coady’s continuing compliance. Coady filed a declaratory-judgment action against Harpo in Illinois state court, seeking a declaration that the confidentiality agreement was unenforceable. Coady said that she planned to work as a journalist and write or report about her experiences as a Harpo employee because those experiences were matters of legitimate public interest. Coady asserted that the confidentiality agreement was overly broad, not limited in duration or geographical scope, and not reasonably necessary to protect Harpo’s legitimate business interests. Harpo moved to dismiss Coady’s action. The trial court granted Harpo’s motion, and Coady appealed to the Illinois Appellate Court.