Columbus Medical Services, LLC v. Thomas
Tennessee Court of Appeals
308 S.W.3d 368 (2009)
- Written by David Bloom, JD
Facts
Columbus Medical Services, LLC (Columbus) (plaintiff), a staffing agency, had an exclusive contract with Tennessee to find candidates for therapist positions at Arlington Developmental Center (Arlington), a residential facility for patients with disabilities. Therapists hired by Columbus entered into employment contracts that contained noncompete provisions prohibiting the therapists from working at Arlington for one year after termination of the therapists’ employment with Columbus. Columbus invested in recruiting and relocating capable hires to work at Arlington and developing good relationships between the therapists and Arlington’s patients. Columbus negotiated the therapists’ employment conditions at Arlington. Columbus did not pay for the specialized training that the therapists were required to receive. As Columbus’s exclusive contract with Tennessee was set to expire, Tennessee awarded the next contract to Columbus’s competitor, Liberty Healthcare Corporation (Liberty) (defendant). Arlington liked Columbus’s therapists and wanted the therapists to stay on after Columbus’s exclusive contract expired and encouraged Liberty to recruit Columbus’s therapists. Liberty hired nine of Columbus’s former therapists (defendants) to continue working at Arlington less than one year after the therapists’ employment with Columbus had ended. Columbus filed suit, claiming that the nine therapists breached the noncompete provisions and that Liberty induced the breaches. The trial court ruled in favor of Columbus. Liberty and the nine therapists appealed, arguing that the noncompete provisions were unenforceable.
Rule of Law
Issue
Holding and Reasoning (Kirby, J.)
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