Hassler v. Circle C Resources
Wyoming Supreme Court
505 P.3d 169 (2022)
- Written by Tammy Boggs, JD
Facts
Circle C Resources (Circle C) (plaintiff) provided day and residential habilitation services. The residential services could be provided to clients in the homes of Circle C’s employees. In 2015, Circle C hired Charlene Hassler (defendant) to provide care in her home. Hassler signed a noncompetition agreement, which restricted her from working in any competitive capacity to Circle C for 24 months after the end of her employment and in any geographic area where Circle C provided services, including in seven named counties of Wyoming. The agreement further provided that if a court were to find that any provision of the noncompetition agreement was unenforceable, then Hassler agreed to abide by reasonable restrictions substituted by the court. Hassler went on to provide full-time care for a client (the client) in her home. In 2017, the client became dissatisfied with the day habilitation services provided by Circle C and decided to switch providers. Hassler ended her employment with Circle C but still provided services to the client, who remained living in Hassler’s home. Circle C sued Hassler for violating the noncompetition agreement. Circle C conceded that the agreement’s duration and geographic restrictions were unreasonable. Circle C wished to restrict Hassler’s ability to compete for 12 months in two counties. On summary judgment, the court found in favor of Circle C by applying the “blue pencil” rule. The court found the noncompetition agreement was enforceable if the restrictions were narrowed to only two counties and 12 months in duration. Hassler appealed, arguing that the noncompetition agreement should be entirely void and unenforceable because it violated public policy.
Rule of Law
Issue
Holding and Reasoning (Kautz, J.)
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