Rem Metals Corp. v. Logan

Rem Metals Corporation (Rem) (plaintiff) employed Forrest Logan (defendant) as a welder. Rem produced precision titanium casings, which it sold to Pratt & Whitney Aircraft Division. Only three companies produced such cases: Rem, Precision Castparts Corporation (Precision), and a smaller company in Michigan. Rem employed only two or three certified welders, including Logan. Logan had learned to weld electrodes of titanium at a previous employer. When Logan joined Rem, he signed two employment contracts that contained noncompetition clauses providing that he would not engage in competition with Rem anywhere in the United States for the period of one year after his employment ended. When Logan started in the welding department at Rem, he earned his certification in less than two weeks. The training did not disclose any trade secrets regarding the welding process. Logan did not interact with customers. At some point, Logan asked for a wage increase, but Rem refused. Logan quit Rem and began working for Precision Castparts. Rem lost out on $25,000 worth of business in the two weeks following Logan’s departure due to a lack of adequate welders. However, Rem successfully trained two welders to Pratt & Whitney’s standards shortly after Logan left. Rem sued Logan to enforce the noncompetition provisions of Logan’s employment contracts. The lower court enjoined Logan from engaging in competition with Rem for six months. Logan appealed.