Quimbee logo
DMCA.com Protection Status

Edwards v. Arthur Andersen LLP

44 Cal.4th 937, 189 P. 3d 285 (2008)

Case BriefRelatedOptions
From our private database of 33,800+ case briefs...

Edwards v. Arthur Andersen LLP

California Supreme Court

44 Cal.4th 937, 189 P. 3d 285 (2008)

Play video

Facts

Raymond Edwards (plaintiff) was hired as a certified public accountant by Arthur Andersen LLP (Andersen) (defendant). Andersen required Edwards to sign a noncompetition agreement, which provided that if Edwards left Andersen, Edwards was prohibited from providing professional services for any client for whom he did work at Andersen for 18 months, as well as from providing professional services to any client of Andersen’s Los Angeles office for 12 months. In 2002, after Andersen was indicted by the United States government in connection with the Enron investigation, Andersen announced that it was selling its tax practice to HSBC USA, Inc. (defendant). HSBC offered Edwards a job but required him to sign a Termination of Non-Compete Agreement (TONC), pursuant to which Andersen would release Edwards from his noncompetition agreement if he released Andersen from any and all claims arising from his employment. Edwards did not sign the TONC. Andersen subsequently terminated Edwards's employment, and HSBC withdrew its job offer. Edwards sued Andersen and HSBC for intentional interference with prospective economic advantage and anti-competitive business practices. Edwards based his suit on California Business and Professions Code section 16600, which stated that except for noncompetition agreements in the sale or dissolution of corporations, partnerships, and limited liability corporations, “every contract by which anyone is restrained from engaging in a lawful profession, trade, or business of any kind is to that extent void.” Edwards argued that his noncompetition agreement with Andersen restrained him from practicing his profession. Andersen argued that some California courts and the Ninth Circuit have interpreted section 16600 to prohibit only broad noncompetition agreements that entirely prohibit someone from engaging in his or her profession. Under that interpretation, Andersen asserted that the noncompetition agreement here was valid because it was not a broad prohibition and only restricted some of Edwards's conduct after he left his employment at Andersen. The trial court entered judgment in Andersen's favor, finding that the noncompetition agreement did not violate section 16600 because it was a narrow restriction that left Edwards with the ability to pursue his profession. The California Court of Appeal reversed, holding among other things that the noncompetition agreement was invalid under section 16600. Andersen appealed to the California Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Chin, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 605,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.

    Unlock this case briefRead our student testimonials
  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

    Learn about our approachRead more about Quimbee

Here's why 605,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 33,800 briefs, keyed to 984 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 605,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 33,800 briefs - keyed to 984 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership