Ag Spectrum Co. v. Elder, No. 16-3113 (8th Cir. 2017)
Annotate this CaseThe Eighth Circuit affirmed the district court's holding that an independent-contractor agreement's noncompete provision was unreasonable and therefore unenforceable. Without controlling precedent from the Iowa Supreme Court, the court predicted that the Iowa Supreme Court would hold that the enforceability of a noncompete provision was a question for the court. In this case, plaintiff developed his own customer base and received only minimal support from Ag Spectrum. The court explained that requiring plaintiff to forsake the customers that he brought to Ag Spectrum as an independent contractor was unreasonable in the circumstances, and plaintiff's business activity fostered fair competition in the marketplace, not unjust enrichment.
Court Description: Smith, Author, with Shepherd, Circuit Judge, and Fenner, District Judge] Civil case - Contracts. The district court did not err in determining that the noncompete provision in plaintiff's contract was unreasonable and unenforceable; without controlling precedent from the Iowa Supreme Court, the court predicts the Iowa Supreme Court would hold that the enforceability of a noncompete provision is a question for the court.
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