Wagner v. Lectrox Corp.

348 N.E.2d 451 (1976)

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Wagner v. Lectrox Corp.

Massachusetts Appeals Court
348 N.E.2d 451 (1976)

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Facts

William Wagner (plaintiff) signed a noncompete contract with the Lectrox Corporation (defendant). The contract restrained Wagner’s ability to be employed by a different company in the field of electrostatics. The contract was sealed, meaning it was sealed with Wagner’s wax, marked as under seal, or both. Wagner had difficulty getting employment because potential employers were concerned about the contractual restraints. Wagner sued Lectrox, seeking a declaration that the contract was invalid. One of Wagner’s arguments was that the contract was invalid because Lectrox had not provided any consideration in exchange for Wagner’s promises regarding the employment constraints. Lectrox moved for summary judgment, arguing that whether it had provided any consideration was irrelevant because the contract was sealed, and sealed contracts did not require consideration. The trial court granted judgment for Lectrox. Wagner appealed to the Massachusetts Appeals Court.

Rule of Law

Issue

Holding and Reasoning (Memorandum)

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