open-agreements 0.7.5 → 0.7.7

package/skills/non-compete-contract-explainer/content/ohio.md

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+---
+jurisdiction: "Ohio"
+slug: ohio
+countryCode: US
+snapshotAsOf: "2026-06-08"
+lastReviewed: "2026-06-03"
+canonicalUrl: https://openagreements.org/legal/non-compete/ohio
+license: CC BY 4.0
+stale: false
+---
+
+> [!IMPORTANT]
+> **Informational only — not legal advice.** This is a snapshot of an OpenAgreements practice note,
+> provided for general information. It is not legal advice, does not create an attorney-client
+> relationship, and is not a substitute for a licensed attorney in the relevant jurisdiction.
+> Laws change; verify against the canonical version before relying on it.
+>
+> **Canonical:** https://openagreements.org/legal/non-compete/ohio · **Snapshot as of:** 2026-06-08 · License: CC BY 4.0 · © UseJunior
+
+# Non-Competes in Ohio[^about]
+
+Ohio enforces non-competes only when the restraint is reasonable under the Raimonde rule, and its courts may reform an overbroad covenant or decline to enforce it at all.
+
+
+## At a glance
+
+| Question | Ohio |
+| --- | --- |
+| **Are non-competes enforceable?** | Allowed if reasonable |
+| **Bottom line** | Ohio enforces an employee non-compete only to the extent it is reasonable under the Raimonde test — no broader than needed to protect the employer, not unduly harsh on the employee, and not injurious to the public. |
+| **Main law or case** | Raimonde v. Van Vlerah, 42 Ohio St. 2d 21 (1975) |
+| **Main exceptions** | Physician public-interest scrutiny; pending S.B. 301 (nonprofit-hospital cap) and S.B. 11 (broad ban) not enacted |
+| **Can a court narrow it?** | Yes — rewrites to reasonable |
+| **Applies to contractors?** | Unclear |
+| **Restriction extended during a breach?** | Yes — a covenant may not expire while enforceability is litigated (Homan) |
+| **Maximum length set by law** | No statutory cap |
+
+## Are employee non-compete agreements enforceable in Ohio? {#employee-noncompetes}
+
+**Short answer.** Yes, sometimes. Ohio is a reasonableness state, not a general ban state. A non-compete is enforceable only to the extent it is reasonable — meaning it is no greater than needed to protect the employer, does not impose undue hardship on the employee, and is not injurious to the public [^raimonde-reasonableness-test].
+
+The controlling standard comes from the Ohio Supreme Court's decision in *Raimonde v. Van Vlerah*, which set out a three-part rule of reasonableness for post-employment restraints [^raimonde-reasonableness-test]. There is no general Ohio non-compete statute for the ordinary workforce; enforceability is judge-made, applied covenant by covenant on its own facts.
+
+Because the test is holistic, no single term is decisive. A court weighs the employer's protectable interest, the burden on the employee, and the public effect together, rather than checking a covenant against fixed numbers.
+
+> [!NOTE]
+> **Practice note.**
+>
+> Do not treat Ohio as either a free-for-all or a ban state. Test every covenant against the three *Raimonde* prongs — employer protection, hardship on the employee, and public injury — before assuming an Ohio restraint is enforceable [^raimonde-reasonableness-test].
+
+## Is continued at-will employment enough consideration for an Ohio non-compete? {#consideration}
+
+**Short answer.** Yes. Unlike some states, Ohio holds that an employer's agreement to continue an at-will employment relationship is itself sufficient consideration for a non-compete an existing employee signs [^lakeland-continued-employment].
+
+In *Lake Land Employment Group of Akron, LLC v. Columber*, the Ohio Supreme Court held that consideration exists when an employer continues an at-will relationship that it could legally have terminated without cause in exchange for the employee's assent to the covenant [^lakeland-continued-employment]. That makes Ohio more employer-favorable on consideration than states that require new, independent value for a mid-employment covenant.
+
+The rule is not a blank check. Continued employment supplies the consideration, but the covenant must still survive the *Raimonde* reasonableness analysis to be enforceable [^q2-raimonde-reasonableness].
+
+> [!CAUTION]
+> **Drafting note.**
+>
+> Do not assume adequate consideration cures an overbroad covenant. Continued at-will employment satisfies *Lake Land*, but a restraint that fails *Raimonde* on time, territory, or scope is still unenforceable [^lakeland-continued-employment][^q2-raimonde-reasonableness].
+
+## What legitimate business interests can support an Ohio non-compete? {#protectable-interests}
+
+**Short answer.** Confidential information, trade secrets, and customer goodwill are the core interests that justify a tailored Ohio restraint. The Ohio Uniform Trade Secrets Act supplies the statutory trade-secret overlay that runs alongside the covenant [^outsa-trade-secret-definition].
+
+*Raimonde* itself lists the factors a court weighs, including whether the employee possessed confidential information or trade secrets and whether the covenant targets unfair competition rather than ordinary competition [^raimonde-confidential-factor]. A covenant that merely suppresses ordinary competition, untethered to a protectable interest, will not stand.
+
+The Ohio Uniform Trade Secrets Act, codified at R.C. 1333.61 through 1333.69, defines a trade secret by the twin tests of independent economic value from secrecy and reasonable efforts to maintain that secrecy [^outsa-trade-secret-definition]. The Act gives a separate remedy: actual or threatened misappropriation may be enjoined regardless of any contract [^outsa-injunction]. A non-solicitation or confidentiality strategy under the Act is often a stronger backstop than a broad non-compete.
+
+> [!CAUTION]
+> **Drafting note.**
+>
+> Do not use an Ohio non-compete to block competition disconnected from a protectable interest. Tie the restraint to identified confidential information, trade secrets, or customer goodwill, and keep a separate confidentiality and trade-secret strategy under R.C. 1333.61 et seq. [^outsa-trade-secret-definition][^raimonde-confidential-factor].
+
+## What duration and geographic scope are reasonable for an Ohio non-compete? {#duration-geography}
+
+**Short answer.** There is no statutory cap. Ohio courts weigh duration and territory together against the employer's actual protectable interest under *Raimonde*, and they may cut back a restraint that reaches further than necessary [^q4-raimonde-factors][^metrohealth-modified].
+
+Because the standard is holistic, geography and duration are evaluated against the employer's real footprint rather than fixed numbers [^q4-raimonde-factors]. A restraint limited to the area and time genuinely needed to protect customer relationships or confidential information is far easier to defend than a long, open-ended, statewide ban.
+
+When a covenant overshoots, an Ohio court may trim it. In *MetroHealth System v. Khandelwal*, the court of appeals upheld a trial court's decision to narrow an overbroad physician covenant — modifying it rather than voiding it — because it was more restrictive than necessary to protect the employer's legitimate interests [^metrohealth-modified].
+
+> [!CAUTION]
+> **Drafting note.**
+>
+> Do not copy a fixed term or radius from another form. Match duration and territory to the employee's role and the employer's actual market, because an Ohio court evaluates the restraint as a whole and there is no safe-harbor number [^q4-raimonde-factors][^metrohealth-modified].
+
+## Will an Ohio court reform or refuse to enforce an overbroad non-compete? {#court-narrowing}
+
+**Short answer.** It depends. *Raimonde* abandoned strict blue-penciling and lets Ohio courts enforce an overbroad covenant only to the extent reasonable, but reformation is discretionary — a court may instead refuse to rewrite an abusively broad covenant [^raimonde-reformation][^kross-discretionary].
+
+*Raimonde* holds that a covenant imposing unreasonable restrictions will be enforced to the extent necessary to protect the employer's legitimate interests, giving Ohio courts the power to modify rather than void [^raimonde-reformation]. But that power is not automatic. In *Kross Acquisition Co. v. Groundworks Ohio, LLC*, the First District confirmed that modifying a covenant is within the trial court's discretion, and it affirmed a refusal to rewrite a covenant so overbroad that reforming it would require the court to rebuild the agreement from scratch [^kross-discretionary].
+
+There is also a real cost to overreaching. In *Cintas Corp. v. Perry*, applying Ohio law, the employer's own prevailing-party fee clause boomeranged: after the covenant failed, the court held the former employee was entitled to recover his attorney's fees and litigation costs under that contract [^cintas-fee-shift].
+
+> [!CAUTION]
+> **Drafting note.**
+>
+> Do not rely on reformation as a safety net for an aggressive Ohio covenant. Draft tiered, severable, reasonable restraints, because a court may refuse to rewrite an overbroad covenant — and a one-sided fee clause can shift fees to the departing employee when the covenant fails [^kross-discretionary][^cintas-fee-shift].
+
+## Can a successor company enforce a non-compete after a merger in Ohio? {#successor-enforcement}
+
+**Short answer.** Yes, after a statutory merger. In *Acordia of Ohio, L.L.C. v. Fishel*, the Ohio Supreme Court held that the surviving company may enforce non-competes the absorbed company's employees signed, as if it had stepped into the original employer's shoes — provided the covenant is reasonable [^acordia-successor].
+
+On reconsideration, the court in *Acordia* clarified that a merged entity can enforce acquired non-compete agreements without separate assignment language, because by operation of the merger statutes it succeeds to the predecessor's contracts [^acordia-successor]. The covenant still has to satisfy *Raimonde* in the successor's hands.
+
+That holding turns on a statutory merger. A deal structured as an asset purchase, or a covenant the parties intend to be personal to the original employer, can raise different assignability questions — so buyers should not assume every restrictive covenant transfers automatically.
+
+> [!CAUTION]
+> **Drafting note.**
+>
+> Do not rely on *Acordia* for every transaction. It addresses covenants that pass by statutory merger; in an asset deal, include express assignment and successor-and-assigns language so the buyer can enforce the restraint [^acordia-successor].
+
+## Does an Ohio non-compete toll or extend during breach or litigation? {#tolling-extension}
+
+**Short answer.** It can. Ohio appellate courts have held that a non-compete may not expire while its enforceability is being litigated, so the restricted period can be effectively extended until the case is resolved [^homan-tolling].
+
+In *Homan, Inc. v. A1 AG Services, L.L.C.*, the Third District adopted the Sixth District's rule that a covenant not to compete may not expire while the enforceability of the contract is being litigated [^homan-tolling]. The court applied that rule to a covenant whose period it had already reformed for reasonableness, so the defendant remained bound for the remaining reasonable term after the litigation concluded.
+
+This judicial tolling is equitable rather than automatic, and it operates against the *Raimonde* reasonableness backdrop [^q7-raimonde-reasonableness]. A contractual extension-on-breach clause must itself be reasonable; an open-ended or indefinite extension risks being cut back like any other overbroad term.
+
+> [!NOTE]
+> **Practice note.**
+>
+> Do not assume a fixed Ohio covenant simply lapses on its stated end date while a dispute is pending. Under *Homan*, the period can be tolled during litigation — but draft any extension-on-breach clause as a reasonable, bounded restraint tied to the breach, not an indefinite one [^homan-tolling][^q7-raimonde-reasonableness].
+
+## Which Ohio workers face special non-compete treatment? {#industry-specific-limits}
+
+**Short answer.** Physicians are the established category receiving special scrutiny. Ohio enforces their covenants but tests them closely under the public-injury prong, and a pending bill would add statutory limits for certain nonprofit-hospital clinicians [^metrohealth-physician-standard][^williams-public-injury][^sb301-healthcare-cap].
+
+Ohio courts apply a heightened public-interest analysis to physician covenants: a restraint is unreasonable where it imposes undue hardship on the physician and is injurious to the public because the physician's services are vital to the community and the demand for that expertise is critical [^metrohealth-physician-standard]. The principle is long-standing — in *Williams v. Hobbs*, the court affirmed findings that a physician's services were vital to the public and that the covenant was injurious to the public [^williams-public-injury].
+
+There is no enacted Ohio statute banning health care non-competes today. A pending bill, Senate Bill 301, would let a nonprofit hospital impose only a limited restriction on certain clinicians — no more than six months and within a fifteen-mile radius — and would void waivers of that protection [^sb301-healthcare-cap]. It has not become law.
+
+> [!NOTE]
+> **Practice note.**
+>
+> Do not draft a physician or other health care non-compete in Ohio as if it were an ordinary commercial restraint. Expect heightened public-interest scrutiny under *MetroHealth* and *Williams*, and monitor Senate Bill 301, which would cap covered hospital clinician covenants if enacted [^metrohealth-physician-standard][^sb301-healthcare-cap].
+
+## Did the FTC's federal non-compete rule change Ohio non-compete law? {#federal-ftc-overlay}
+
+**Short answer.** No. The FTC's 2024 nationwide Non-Compete Rule was set aside by a federal court before it took effect, so Ohio non-competes remain governed by Ohio common law [^ryan-ftc-set-aside].
+
+In *Ryan LLC v. Federal Trade Commission*, the court held the FTC lacked statutory authority to issue the rule and that the rule was arbitrary and capricious [^ryan-ftc-authority]. It set the rule aside with nationwide effect so that it would not be enforced or take effect [^ryan-ftc-set-aside].
+
+That outcome does not make every Ohio covenant enforceable. It simply removes the FTC rule as a nationwide overlay and leaves Ohio's *Raimonde* reasonableness analysis in control.
+
+"The Non-Compete Rule, 16 C.F.R. § 910.1–.6, is hereby SET ASIDE and shall not be enforced or otherwise take effect on September 4, 2024, or thereafter."[^ryan-ftc-set-aside]
+
+## What Ohio non-compete reform efforts should employers watch? {#pending-reform}
+
+**Short answer.** None is law yet. The headline proposal, Senate Bill 11, would broadly prohibit employer non-competes, but it remains in committee and would apply only prospectively if enacted [^sb11-prohibition][^sb11-prospective].
+
+Senate Bill 11 would bar an employer from entering into, presenting, or enforcing an agreement that prevents a worker from taking other work or operating a business after the employment relationship ends [^sb11-prohibition]. Crucially, even if it passed, the bill voids only agreements entered into, modified, or extended on or after its effective date — it would not reach back to invalidate covenants already in place [^sb11-prospective].
+
+The enacted baseline therefore remains common-law reasonableness under *Raimonde*, plus the trade-secret overlay. These bills signal a possible direction of travel, not current law.
+
+> [!NOTE]
+> **Practice note.**
+>
+> Treat Senate Bill 11 as a monitoring item, not present Ohio law. Recheck the Ohio General Assembly's bill status before changing forms or telling workers that Ohio has banned non-competes, and note that S.B. 11 as drafted would apply only to agreements made or modified after its effective date [^sb11-prohibition][^sb11-prospective].
+
+[^about]: By Steven Obiajulu, J.D. Published by [openagreements.org](https://openagreements.org) · Maintained by [UseJunior](https://usejunior.com). Last reviewed 2026-06-03. License: CC BY 4.0. Steven Obiajulu, J.D. is admitted in New York, not Ohio. This article synthesizes Ohio primary law and is not legal advice from a Ohio-admitted attorney. This article is for informational purposes only and does not create an attorney-client relationship.
+
+[^raimonde-reasonableness-test]: **Raimonde v. Van Vlerah** — "A covenant restraining an employee from competing with his former employer upon termination of employment is reasonable if it is no greater than is required for the protection of the employer, does not impose undue hardship on the employee, and is not injurious to the public." *Raimonde v. Van Vlerah, 42 Ohio St. 2d 21, 325 N.E.2d 544 (1975).* <https://www.courtlistener.com/opinion/6865409/raimonde-v-van-vlerah/#:~:text=A%20covenant%20restraining%20an%20employee,not%20injurious%20to%20the%20public.>
+
+[^lakeland-continued-employment]: **Lake Land Employment Group of Akron, LLC v. Columber** — "We therefore hold that consideration exists to support a noncompetition agreement when, in exchange for the assent of an at-will employee to a proffered noncompetition agreement, the employer continues an at-will employment relationship that could legally be terminated without cause." *Lake Land Emp. Group of Akron, LLC v. Columber, 101 Ohio St. 3d 242, 2004-Ohio-786.* <https://www.courtlistener.com/opinion/6892723/lake-land-employment-group-of-akron-llc-v-columber/#:~:text=We%20therefore%20hold%20that%20consideration,legally%20be%20terminated%20without%20cause.>
+
+[^q2-raimonde-reasonableness]: **Raimonde v. Van Vlerah** — "A covenant restraining an employee from competing with his former employer upon termination of employment is reasonable if it is no greater than is required for the protection of the employer, does not impose undue hardship on the employee, and is not injurious to the public." *Raimonde v. Van Vlerah, 42 Ohio St. 2d 21, 325 N.E.2d 544 (1975).* <https://www.courtlistener.com/opinion/6865409/raimonde-v-van-vlerah/#:~:text=A%20covenant%20restraining%20an%20employee,not%20injurious%20to%20the%20public.>
+
+[^outsa-trade-secret-definition]: **Ohio Rev. Code § 1333.61** — "(1) It derives independent economic value, actual or potential, from not being generally known to, and not being readily ascertainable by proper means by, other persons who can obtain economic value from its disclosure or use.(2) It is the subject of efforts that are reasonable under the circumstances to maintain its secrecy." *Ohio Rev. Code § 1333.61(D).* <https://codes.ohio.gov/ohio-revised-code/section-1333.61>
+
+[^raimonde-confidential-factor]: **Raimonde v. Van Vlerah** — "whether the employee is possessed with confidential information or trade secrets; whether the covenant seeks to eliminate competition which would be unfair to the employer or merely seeks to eliminate ordinary competition" *Raimonde v. Van Vlerah, 42 Ohio St. 2d 21, 325 N.E.2d 544 (1975).* <https://www.courtlistener.com/opinion/6865409/raimonde-v-van-vlerah/#:~:text=whether%20the%20employee%20is%20possessed,seeks%20to%20eliminate%20ordinary%20competition>
+
+[^outsa-injunction]: **Ohio Rev. Code § 1333.62** — "Actual or threatened misappropriation may be enjoined." *Ohio Rev. Code § 1333.62(A).* <https://codes.ohio.gov/ohio-revised-code/section-1333.62>
+
+[^q4-raimonde-factors]: **Raimonde v. Van Vlerah** — "A covenant restraining an employee from competing with his former employer upon termination of employment is reasonable if it is no greater than is required for the protection of the employer, does not impose undue hardship on the employee, and is not injurious to the public." *Raimonde v. Van Vlerah, 42 Ohio St. 2d 21, 325 N.E.2d 544 (1975).* <https://www.courtlistener.com/opinion/6865409/raimonde-v-van-vlerah/#:~:text=A%20covenant%20restraining%20an%20employee,not%20injurious%20to%20the%20public.>
+
+[^metrohealth-modified]: **MetroHealth System v. Khandelwal** — "In short, evidence presented at the hearing supported the trial court’s finding that the 2015 noncompete agreement was more restrictive than necessary but that it could be modified to protect MetroHealth’s legitimate business interests." *MetroHealth Sys. v. Khandelwal, 2022-Ohio-77, 183 N.E.3d 590 (8th Dist.).* <https://www.courtlistener.com/opinion/6205147/metrohealth-sys-v-khandelwal/#:~:text=In%20short%2C%20evidence%20presented%20at,protect%20MetroHealth%E2%80%99s%20legitimate%20business%20interests.>
+
+[^raimonde-reformation]: **Raimonde v. Van Vlerah** — "Courts are empowered to modify or amend employment agreements to achieve such results." *Raimonde v. Van Vlerah, 42 Ohio St. 2d 21, 325 N.E.2d 544 (1975).* <https://www.courtlistener.com/opinion/6865409/raimonde-v-van-vlerah/#:~:text=Courts%20are%20empowered%20to%20modify,agreements%20to%20achieve%20such%20results.>
+
+[^kross-discretionary]: **Kross Acquisition Co. v. Groundworks Ohio, LLC** — "We agree that it is within a trial court’s discretion to modify a noncompetition agreement, and so we review its decision not to modify such an agreement for an abuse of discretion." *Kross Acquisition Co. v. Groundworks Ohio, LLC, 2024-Ohio-592, 236 N.E.3d 453 (1st Dist.).* <https://www.courtlistener.com/opinion/9475789/kross-acquisition-co-llc-v-groundworks-ohio-llc/#:~:text=We%20agree%20that%20it%20is,for%20an%20abuse%20of%20discretion.>
+
+[^cintas-fee-shift]: **Cintas Corp. v. Perry** — "The district court correctly concluded Perry was entitled to attorney’s fees and litigation costs under the employment agreement." *Cintas Corp. v. Perry, 517 F.3d 459 (7th Cir. 2008).* <https://www.courtlistener.com/opinion/1462207/cintas-corporation-v-perry/#:~:text=The%20district%20court%20correctly%20concluded,costs%20under%20the%20employment%20agreement.>
+
+[^acordia-successor]: **Acordia of Ohio, L.L.C. v. Fishel** — "We hold that the L.L.C. may enforce the noncompete agreements as if it had stepped into the shoes of the original contracting companies, provided that the noncompete agreements are reasonable under the circumstances of this case." *Acordia of Ohio, L.L.C. v. Fishel, 133 Ohio St. 3d 356, 2012-Ohio-4648, 978 N.E.2d 823.* <https://www.courtlistener.com/opinion/2690659/acordia-of-ohio-llc-v-fishel/#:~:text=We%20hold%20that%20the%20L.L.C.,the%20circumstances%20of%20this%20case.>
+
+[^homan-tolling]: **Homan, Inc. v. A1 AG Services, L.L.C.** — "The Sixth Appellate District has held that a covenant not to compete may not expire while the enforceability of that contract is being litigated." *Homan, Inc. v. A1 AG Servs., L.L.C., 175 Ohio App. 3d 51, 2008-Ohio-277, 885 N.E.2d 253 (3d Dist.).* <https://www.courtlistener.com/opinion/3953241/homan-inc-v-a1-ag-services-llc/#:~:text=The%20Sixth%20Appellate%20District%20has,that%20contract%20is%20being%20litigated.>
+
+[^q7-raimonde-reasonableness]: **Raimonde v. Van Vlerah** — "A covenant restraining an employee from competing with his former employer upon termination of employment is reasonable if it is no greater than is required for the protection of the employer, does not impose undue hardship on the employee, and is not injurious to the public." *Raimonde v. Van Vlerah, 42 Ohio St. 2d 21, 325 N.E.2d 544 (1975).* <https://www.courtlistener.com/opinion/6865409/raimonde-v-van-vlerah/#:~:text=A%20covenant%20restraining%20an%20employee,not%20injurious%20to%20the%20public.>
+
+[^metrohealth-physician-standard]: **MetroHealth System v. Khandelwal** — "A covenant restraining a physician-employee from competing with his employer upon termination of employment is unreasonable where it imposes undue hardship on the physician and is injurious to the public, the physician’s services are vital to the health, care and treatment of the public, and the demand for his medical expertise is critical to the people in the community." *MetroHealth Sys. v. Khandelwal, 2022-Ohio-77, 183 N.E.3d 590 (8th Dist.).* <https://www.courtlistener.com/opinion/6205147/metrohealth-sys-v-khandelwal/#:~:text=A%20covenant%20restraining%20a%20physician%2Demployee,the%20people%20in%20the%20community.>
+
+[^williams-public-injury]: **Williams v. Hobbs** — "The covenant imposes an undue hardship on the plaintiff, and also, it is injurious to the public." *Williams v. Hobbs, 9 Ohio App. 3d 331, 460 N.E.2d 287 (10th Dist. 1983).* <https://www.courtlistener.com/opinion/4007467/williams-v-hobbs/#:~:text=The%20covenant%20imposes%20an%20undue,is%20injurious%20to%20the%20public.>
+
+[^sb301-healthcare-cap]: **Ohio S.B. 301 (136th General Assembly)** — "the employee will refrain, for a period not to exceed six months, from obtaining employment within a radius of fifteen miles of the physical location where the employee was employed with the hospital." *S.B. 301, 136th Gen. Assemb. (Ohio 2025).* <https://www.legislature.ohio.gov/legislation/136/sb301>
+
+[^ryan-ftc-set-aside]: **Ryan LLC v. Federal Trade Commission** — "The Non-Compete Rule, 16 C.F.R. § 910.1–.6, is hereby SET ASIDE and shall not be enforced or otherwise take effect on September 4, 2024, or thereafter." *Ryan LLC v. Fed. Trade Comm'n, 746 F. Supp. 3d 369 (N.D. Tex. 2024).* <https://www.courtlistener.com/opinion/10205745/ryan-llc-v-federal-trade-commission/#:~:text=The%20Non%2DCompete%20Rule%2C%2016%20C.F.R.,September%204%2C%202024%2C%20or%20thereafter.>
+
+[^ryan-ftc-authority]: **Ryan LLC v. Federal Trade Commission** — "In sum, the Court concludes that the FTC lacks statutory authority to promulgate the Non- Compete Rule, and that the Rule is arbitrary and capricious." *Ryan LLC v. Fed. Trade Comm'n, 746 F. Supp. 3d 369 (N.D. Tex. 2024).* <https://www.courtlistener.com/opinion/10205745/ryan-llc-v-federal-trade-commission/#:~:text=In%20sum%2C%20the%20Court%20concludes%20that,Rule%20is%20arbitrary%20and%20capricious.>
+
+[^sb11-prohibition]: **Ohio S.B. 11 (136th General Assembly)** — "Beginning on the effective date of this section, no employer shall enter into, attempt to enter into, present to a worker or prospective worker as a term of hire, or attempt to enforce an agreement, or part of an agreement, that prohibits the worker from, penalizes the worker for, or functions to prevent the worker from seeking or accepting work with a person, or operating a business, after the conclusion of the relationship between the employer and worker, including any of the following:" *S.B. 11, 136th Gen. Assemb. (Ohio 2025).* <https://www.legislature.ohio.gov/legislation/136/sb11>
+
+[^sb11-prospective]: **Ohio S.B. 11 (136th General Assembly)** — "An agreement, or part of an agreement, between an employer and worker entered into, modified, or extended on or after the effective date of this section that is prohibited under division (A) of this section is void." *S.B. 11, 136th Gen. Assemb. (Ohio 2025).* <https://www.legislature.ohio.gov/legislation/136/sb11>

package/skills/non-compete-contract-explainer/content/oklahoma.md

@@ -0,0 +1,196 @@
+---
+jurisdiction: "Oklahoma"
+slug: oklahoma
+countryCode: US
+snapshotAsOf: "2026-06-08"
+lastReviewed: "2026-06-03"
+canonicalUrl: https://openagreements.org/legal/non-compete/oklahoma
+license: CC BY 4.0
+stale: false
+---
+
+> [!IMPORTANT]
+> **Informational only — not legal advice.** This is a snapshot of an OpenAgreements practice note,
+> provided for general information. It is not legal advice, does not create an attorney-client
+> relationship, and is not a substitute for a licensed attorney in the relevant jurisdiction.
+> Laws change; verify against the canonical version before relying on it.
+>
+> **Canonical:** https://openagreements.org/legal/non-compete/oklahoma · **Snapshot as of:** 2026-06-08 · License: CC BY 4.0 · © UseJunior
+
+# Non-Competes in Oklahoma[^about]
+
+Oklahoma voids employee non-compete agreements by statute and allows only narrow exceptions for customer non-solicitation, employee anti-raiding, and the sale of a business.
+
+
+## At a glance
+
+| Question | Oklahoma |
+| --- | --- |
+| **Are non-competes enforceable?** | Banned |
+| **Bottom line** | Oklahoma voids employee non-competes by statute, permitting only narrow carve-outs for direct customer non-solicitation, employee anti-raiding, and sale-of-business or partnership-dissolution covenants. |
+| **Main law or case** | Okla. Stat. tit. 15, § 217 |
+| **Main exceptions** | Sale of goodwill (§ 218); partnership dissolution (§ 219); direct customer non-solicit (§ 219A); employee anti-raiding (§ 219B); trade-secret clauses outside the ban |
+| **Can a court narrow it?** | No |
+| **Applies to contractors?** | Unclear |
+| **Restriction extended during a breach?** | Not addressed |
+| **Maximum length set by law** | No statutory limit on the ban; sale covenants limited to a county and contiguous counties |
+
+## Are employee non-compete agreements enforceable in Oklahoma? {#employee-noncompetes}
+
+**Short answer.** No. Oklahoma voids employee non-compete agreements by statute. A contract that restrains someone from exercising a lawful profession, trade, or business is void to that extent, except for the narrowly drawn covenants Oklahoma statutes specifically permit: sale-of-goodwill covenants (§ 218), partnership-dissolution covenants (§ 219), direct solicitation of established customers (§ 219A), and employee anti-raiding clauses (§ 219B) [^stat-217-general-void][^stat-219a-void-clause].
+
+This makes Oklahoma one of the most employee-protective jurisdictions in the country. Unlike a reasonableness state, Oklahoma does not ask whether a non-compete is reasonable in duration or geography — a covenant that bars a former employee from competing is simply outside the statute and therefore void. Oklahoma courts have applied that rule to strike conventional non-competes as exceeding what § 219A allows [^howard-noncompete-void].
+
+"The non-competition contracts go well beyond the bounds of what is allowable under § 219A and violate the legislatively expressed public policy."[^howard-noncompete-void]
+
+The U.S. Supreme Court later vacated that 2011 decision on arbitration-procedure grounds, so the void rule's firmest anchors are the statute itself and the Court of Civil Appeals' decision in *Autry v. Acosta, Inc.*, discussed below [^stat-217-general-void].
+
+What an Oklahoma employer *can* protect instead is a defined slice: direct solicitation of established customers, raiding of its workforce, the goodwill it buys when it acquires a business, and its trade secrets and confidential information. Each of those is addressed in its own question below.
+
+> [!NOTE]
+> **Practice note.**
+>
+> Do not paper an Oklahoma employee with an out-of-state non-compete form and assume a court will narrow it to something enforceable. Oklahoma treats a conventional employee non-compete as void rather than reforming it, so the realistic question is which permitted covenant — customer non-solicitation, anti-raiding, or confidentiality — actually protects the interest at stake [^stat-217-general-void][^howard-noncompete-void].
+
+## What customer non-solicitation restrictions does Oklahoma allow? {#customer-nonsolicitation}
+
+**Short answer.** Only a narrow one. Under 15 O.S. § 219A a former employee may compete, but the agreement may bar the employee from *directly* soliciting the *established customers* of the former employer. A clause that reaches further — indirect solicitation, or prospective and former customers — is void [^stat-219a-rule][^autry-no-sever].
+
+The statute permits a tightly drawn customer non-solicitation covenant and nothing broader [^stat-219a-rule].
+
+"A person who makes an agreement with an employer, whether in writing or verbally, not to compete with the employer after the employment relationship has been terminated, shall be permitted to engage in the same business as that conducted by the former employer or in a similar business as that conducted by the former employer as long as the former employee does not directly solicit the sale of goods, services or a combination of goods and services from the established customers of the former employer."[^stat-219a-rule]
+
+Two drafting traps void these clauses. First, the word *indirectly*. In *Autry v. Acosta, Inc.*, the Oklahoma Court of Civil Appeals held that a covenant barring *direct or indirect* solicitation violated § 219A — and, critically, the court refused to save it by striking the offending word [^autry-no-sever][^autry-void].
+
+"We find that the remedy for this Non-Solicitation Agreement's shortcomings is not quite that simple and it cannot be made to comply with § 219A by merely deleting the word ‘indirectly.’"[^autry-no-sever]
+
+Second, even a covenant that tracks the statutory language must still be reasonable. In *Inergy Propane, LLC v. Lundy*, the court indicated that § 219A did not displace the common-law rule of reason for the duration and scope of a customer non-solicitation clause [^inergy-rule-of-reason]. Practitioners often use shorter durations — commonly two years or less — as a risk-control measure; no statutory safe harbor fixes that term.
+
+> [!CAUTION]
+> **Drafting note.**
+>
+> Limit a customer non-solicitation clause to *direct* solicitation of *established* customers, and do not add *indirectly*, *prospective customers*, or *former customers*. Oklahoma courts will void the whole provision rather than blue-pencil the extra words out of it [^autry-no-sever][^autry-void].
+
+## Can an Oklahoma employer restrict soliciting its employees? {#employee-nonsolicitation}
+
+**Short answer.** Yes. 15 O.S. § 219B expressly allows an employee anti-raiding covenant that bars a former employee from soliciting the employer's employees or independent contractors — and, unlike the customer rule, it may reach *direct or indirect* solicitation [^stat-219b-antiraid].
+
+Section 219B was enacted to give employers broader protection for their workforce than § 219A gives them for their customers. It removes employee-anti-raiding clauses from the general restraint-of-trade prohibition altogether [^stat-219b-antiraid].
+
+"A contract or contractual provision which prohibits an employee or independent contractor of a person or business from soliciting, directly or indirectly, actively or inactively, the employees or independent contractors of that person or business to become employees or independent contractors of another person or business shall not be construed as a restraint from exercising a lawful profession, trade or business of any kind."[^stat-219b-antiraid]
+
+> [!CAUTION]
+> **Drafting note.**
+>
+> Section 219B authorizes restrictions on *soliciting* employees, not a flat no-hire ban. A clause that purports to stop a former employee from hiring a colleague who applies on their own initiative — without any solicitation — is on far weaker ground, because it reaches beyond the solicitation the statute protects [^stat-219b-antiraid].
+
+## Are non-competes tied to the sale of a business enforceable in Oklahoma? {#sale-of-business}
+
+**Short answer.** Yes, within statutory limits. Under 15 O.S. § 218 the seller of a business's goodwill may agree not to compete within a specified county and contiguous counties, or a specified city or town. A parallel rule in § 219 allows the same on the dissolution of a partnership [^stat-218-goodwill][^stat-219-partners].
+
+This is the most important practical exception, and Oklahoma courts enforce it [^berry-218-goodwill].
+
+"We have consistently upheld non-compete agreements to protect business goodwill pursuant to § 218."[^berry-218-goodwill]
+
+The sale-of-business exception differs from the employment rules in a crucial way: it comes with a statutory blue-pencil. If a goodwill covenant reaches too far geographically, a court may scale it back to the primary county and contiguous counties rather than voiding it [^stat-218-goodwill][^eakle-218-reform].
+
+"The Oklahoma Supreme Court has held that non-compete agreements in connection with the sale of goodwill, which are otherwise valid, are subject to modification with respect to the territorial restrictions found in section 218."[^eakle-218-reform]
+
+The exception applies only to a genuine sale of goodwill. A token equity stake should not be assumed to convert an ordinary employment non-compete into a protected sale-of-business covenant; in *Bayly, Martin & Fay, Inc. v. Pickard* the Oklahoma Supreme Court indicated that only the sale of an appreciable ownership interest can carry a business's goodwill under § 218 [^bayly-appreciable-interest].
+
+> [!NOTE]
+> **Practice note.**
+>
+> The geographic ceiling in § 218 is a county-and-contiguous-counties (or a single city or town) footprint — far narrower than the multi-state radii common in sale agreements. Draft to that ceiling from the start; the statutory blue-pencil reduces overbroad geography to the primary county and its neighbors, not to whatever regional scope the parties wrote [^stat-218-goodwill][^eakle-218-reform].
+
+## Does continued employment count as consideration for an Oklahoma restrictive covenant? {#consideration}
+
+**Short answer.** It is unsettled. Oklahoma has not squarely decided whether continued at-will employment, by itself, is sufficient consideration for a restrictive covenant signed mid-employment. Whatever the consideration, the covenant must still fit § 219A or § 219B, or it is void regardless [^stat-219a-void-consideration].
+
+Practitioners often assume Oklahoma follows the majority rule that continued employment suffices, but no Oklahoma decision settles the point for a covenant introduced after hiring. The conservative course is to provide fresh, identifiable consideration — a bonus, a raise, a promotion, or access to confidential information — when an existing employee is asked to sign.
+
+> [!NOTE]
+> **Practice note.**
+>
+> Treat mid-employment consideration as an open question, not a solved one. Pair any covenant presented to a current employee with new and identifiable consideration, and remember that adequate consideration does not rescue a covenant whose substance conflicts with § 219A [^stat-219a-void-consideration].
+
+## Are confidentiality and trade-secret protections still enforceable in Oklahoma? {#trade-secrets}
+
+**Short answer.** Yes. A confidentiality or trade-secret clause does not restrain a person from working — it restrains the misuse of protected information — so it sits outside the § 217 ban. The Oklahoma Uniform Trade Secrets Act backs that protection with injunctive relief and damages [^outsa-injunction].
+
+Because the Trade Secrets Act protects the information rather than the employment relationship, it is the most durable tool an Oklahoma employer has for guarding competitively sensitive material — and it operates whether or not any restrictive covenant survives [^outsa-injunction].
+
+"Actual or threatened misappropriation may be enjoined."[^outsa-injunction]
+
+## Can a choice-of-law or forum-selection clause escape Oklahoma's non-compete ban? {#choice-of-law}
+
+**Short answer.** Sometimes. An Oklahoma court will not apply a contractually chosen foreign law if doing so would violate Oklahoma public policy — so a Delaware or Texas choice-of-law clause will not, by itself, resurrect a void employee non-compete. But a mandatory forum-selection clause is a different lever: a federal court in Oklahoma has enforced one to transfer the dispute out of Oklahoma, after which the employer obtained injunctive relief under the chosen state's law [^eakle-public-policy][^griffin-order][^griffin-forum-selection].
+
+The choice-of-law limit is well settled [^eakle-public-policy].
+
+"As this general rule recognizes, however, the forum court will not apply the law chosen by the contracting parties should doing so violate the public policy of the forum state."[^eakle-public-policy]
+
+That public-policy backstop is why a foreign choice-of-law clause does not save an employee non-compete that § 217 voids. But it is not absolute: where the covenant fits an exception Oklahoma itself recognizes — for example a sale-of-goodwill covenant under § 218 — courts have applied the parties' chosen law and enforced the deal.
+
+The sharper risk for employees comes from forum selection. In the 2025 *Griffin v. Stryker* litigation, the U.S. District Court for the Northern District of Oklahoma enforced a mandatory Michigan forum-selection clause and transferred an Oklahoma employee's declaratory-judgment action out of Oklahoma — even though the court acknowledged it would *likely* find the covenants void if the case stayed [^griffin-order]. A firm summary of the litigation reports that the employer then obtained a preliminary injunction in Michigan [^griffin-forum-selection].
+
+"Plaintiff has therefore not met his burden of showing that exceptional circumstances exist that counsel against transfer to the contractually selected forum."[^griffin-order]
+
+> [!NOTE]
+> **Practice note.**
+>
+> An Oklahoma employee facing an out-of-state employer should treat a mandatory forum-selection clause as the real threat, not the governing-law clause. Oklahoma's public policy can defeat a foreign governing law, but it may not be enough to keep the case in Oklahoma if the contract requires litigation elsewhere [^griffin-order].
+
+## What recent legislative developments affect Oklahoma non-competes? {#recent-developments}
+
+**Short answer.** The framework held steady through the last attempt to loosen it. In 2024 the Legislature passed Senate Bill 1543, which would have broadened § 219A to let employers bar customer solicitation *directly or indirectly* and to reach *independent contractors* — but Governor Stitt vetoed it, and the veto was not overridden [^sb1543-enrolled][^mcafeetaft-sb1543-veto].
+
+The enrolled bill would have rewritten the operative clause so that a covenant could restrict solicitation *directly or indirectly, actively or inactively* — the very breadth *Autry* forbids today [^sb1543-enrolled].
+
+"A person who makes an agreement with an employer, whether in writing or verbally, not to compete with the employer after the employment relationship has been terminated, shall be permitted to engage in the same business as that conducted by the former employer or in a similar business as that conducted by the former employer as long as the former employee does not directly solicit, directly or indirectly, actively or inactively, the sale of goods, services or a combination of goods and services from the established customers or independent contractors of the former employer."[^sb1543-enrolled]
+
+The veto left the strict § 219A regime — and the *Autry* prohibition on reaching indirect solicitation — fully in place. Employers should keep watching for similar bills in future sessions, but for now the narrow direct-solicitation-of-established-customers rule is unchanged [^mcafeetaft-sb1543-veto].
+
+"UPDATE: Oklahoma Governor Kevin Stitt vetoed this bill April 30, 2024, and the Legislature did not override the veto in the 2024 legislative session."[^mcafeetaft-sb1543-veto]
+
+[^about]: By Steven Obiajulu, J.D. Published by [openagreements.org](https://openagreements.org) · Maintained by [UseJunior](https://usejunior.com). Last reviewed 2026-06-03. License: CC BY 4.0. Steven Obiajulu, J.D. is admitted in New York, not Oklahoma. This article synthesizes Oklahoma primary law and is not legal advice from a Oklahoma-admitted attorney. This article is for informational purposes only and does not create an attorney-client relationship.
+
+[^stat-217-general-void]: **15 O.S. § 217** — "Every contract by which any one is restrained from exercising a lawful profession, trade or business of any kind, otherwise than as provided by Sections 218 and 219 of this title, or otherwise than as provided by Section 2 of this act, is to that extent void." *Okla. Stat. tit. 15, § 217.* <https://oksenate.gov/sites/default/files/2022-05/os15.pdf>
+
+[^stat-219a-void-clause]: **15 O.S. § 219A** — "Any provision in a contract between an employer and an employee in conflict with the provisions of this section shall be void and unenforceable." *Okla. Stat. tit. 15, § 219A(B).* <https://oksenate.gov/sites/default/files/2022-05/os15.pdf>
+
+[^howard-noncompete-void]: **Howard v. Nitro-Lift Technologies, L.L.C.** — "The non-competition contracts go well beyond the bounds of what is allowable under § 219A and violate the legislatively expressed public policy." *Howard v. Nitro-Lift Techs., L.L.C., 2011 OK 98, 273 P.3d 20, vacated on other grounds sub nom. Nitro-Lift Techs., L.L.C. v. Howard, 568 U.S. 17 (2012).* <https://www.courtlistener.com/opinion/5327051/howard-v-nitro-lift-technologies-llc/#:~:text=The%20non%2Dcompetition%20contracts%20go%20well,the%20legislatively%20expressed%20public%20policy.>
+
+[^stat-219a-rule]: **15 O.S. § 219A** — "A person who makes an agreement with an employer, whether in writing or verbally, not to compete with the employer after the employment relationship has been terminated, shall be permitted to engage in the same business as that conducted by the former employer or in a similar business as that conducted by the former employer as long as the former employee does not directly solicit the sale of goods, services or a combination of goods and services from the established customers of the former employer." *Okla. Stat. tit. 15, § 219A(A).* <https://oksenate.gov/sites/default/files/2022-05/os15.pdf>
+
+[^autry-no-sever]: **Autry v. Acosta, Inc.** — "We find that the remedy for this Non-Solicitation Agreement's shortcomings is not quite that simple and it cannot be made to comply with § 219A by merely deleting the word ‘indirectly.’" *Autry v. Acosta, Inc., 2018 OK CIV APP 8, 410 P.3d 1017.* <https://www.courtlistener.com/opinion/4520541/autry-v-acosta-inc/#:~:text=We%20find%20that%20the%20remedy,merely%20deleting%20the%20word%20%E2%80%9Cindirectly.%E2%80%9D>
+
+[^autry-void]: **Autry v. Acosta, Inc.** — "Examined under the lens of § 219A, the Non-Solicitation Agreement is void and unenforceable as against Oklahoma's public policy expressed by the Legislature's enactment of that section." *Autry v. Acosta, Inc., 2018 OK CIV APP 8, 410 P.3d 1017.* <https://www.courtlistener.com/opinion/4520541/autry-v-acosta-inc/#:~:text=Examined%20under%20the%20lens%20of,Legislature's%20enactment%20of%20that%20section.>
+
+[^inergy-rule-of-reason]: **Inergy Propane, LLC v. Lundy** — "That does not, however, require abandonment of the rule of reason analysis required by previously established case law." *Inergy Propane, LLC v. Lundy, 2009 OK CIV APP 8, 219 P.3d 547.* <https://www.courtlistener.com/opinion/2629577/inergy-propane-llc-v-lundy/#:~:text=That%20does%20not%2C%20however%2C%20require,by%20previously%20established%20case%20law.>
+
+[^stat-219b-antiraid]: **15 O.S. § 219B** — "A contract or contractual provision which prohibits an employee or independent contractor of a person or business from soliciting, directly or indirectly, actively or inactively, the employees or independent contractors of that person or business to become employees or independent contractors of another person or business shall not be construed as a restraint from exercising a lawful profession, trade or business of any kind." *Okla. Stat. tit. 15, § 219B.* <https://oksenate.gov/sites/default/files/2022-05/os15.pdf>
+
+[^stat-218-goodwill]: **15 O.S. § 218** — "One who sells the goodwill of a business may agree with the buyer to refrain from carrying on a similar business within a specified county and any county or counties contiguous thereto, or a specified city or town or any part thereof, so long as the buyer, or any person deriving title to the goodwill from him carries on a like business therein. Provided, that any such agreement which is otherwise lawful but which exceeds the territorial limitations specified by this section may be deemed valid, but only within the county comprising the primary place of the conduct of the subject business and within any counties contiguous thereto." *Okla. Stat. tit. 15, § 218.* <https://oksenate.gov/sites/default/files/2022-05/os15.pdf>
+
+[^stat-219-partners]: **15 O.S. § 219** — "Partners may, upon or in anticipation of a dissolution of the partnership, agree that none of them will carry on a similar business within a specified county and any county or counties contiguous thereto, or a specified city or town or any part thereof. Provided, that any such agreement which is otherwise lawful but which exceeds the territorial limitations specified by this section may be deemed valid, but only within the county comprising the primary place of the conduct of the business of the subject partnership and within any counties contiguous thereto." *Okla. Stat. tit. 15, § 219.* <https://oksenate.gov/sites/default/files/2022-05/os15.pdf>
+
+[^berry-218-goodwill]: **Berry & Berry Acquisitions, LLC v. BFN Props. LLC** — "We have consistently upheld non-compete agreements to protect business goodwill pursuant to § 218." *Berry & Berry Acquisitions, LLC v. BFN Props. LLC, 2018 OK 27, 416 P.3d 1061.* <https://www.courtlistener.com/opinion/4483518/berry-berry-acquisitions-llc-v-bfn-props-llc/#:~:text=We%20have%20consistently%20upheld%20non%2Dcompete,goodwill%20pursuant%20to%20%C2%A7%20218.>
+
+[^eakle-218-reform]: **Eakle v. Grinnell Corp.** — "The Oklahoma Supreme Court has held that non-compete agreements in connection with the sale of goodwill, which are otherwise valid, are subject to modification with respect to the territorial restrictions found in section 218." *Eakle v. Grinnell Corp., 272 F. Supp. 2d 1304 (E.D. Okla. 2003).* <https://www.courtlistener.com/opinion/2296282/eakle-v-grinnell-corp/#:~:text=The%20Oklahoma%20Supreme%20Court%20has,restrictions%20found%20in%20section%20218.>
+
+[^bayly-appreciable-interest]: **Bayly, Martin & Fay, Inc. v. Pickard** — "Court held that the sale of an appreciable amount of stock, there 20%, could constitute a sale of good will within the meaning of § 218." *Bayly, Martin & Fay, Inc. v. Pickard, 1989 OK 122, 780 P.2d 1168.* <https://www.courtlistener.com/opinion/1190912/bayly-martin-fay-inc-v-pickard/#:~:text=Court%20held%20that%20the%20sale,the%20meaning%20of%20%C2%A7%20218.>
+
+[^stat-219a-void-consideration]: **15 O.S. § 219A** — "Any provision in a contract between an employer and an employee in conflict with the provisions of this section shall be void and unenforceable." *Okla. Stat. tit. 15, § 219A(B).* <https://oksenate.gov/sites/default/files/2022-05/os15.pdf>
+
+[^outsa-injunction]: **78 O.S. § 87** — "Actual or threatened misappropriation may be enjoined." *Okla. Stat. tit. 78, § 87(A).* <https://oksenate.gov/sites/default/files/2022-05/os78.pdf>
+
+[^eakle-public-policy]: **Eakle v. Grinnell Corp.** — "As this general rule recognizes, however, the forum court will not apply the law chosen by the contracting parties should doing so violate the public policy of the forum state." *Eakle v. Grinnell Corp., 272 F. Supp. 2d 1304 (E.D. Okla. 2003).* <https://www.courtlistener.com/opinion/2296282/eakle-v-grinnell-corp/#:~:text=As%20this%20general%20rule%20recognizes%2C,policy%20of%20the%20forum%20state.>
+
+[^griffin-order]: **Griffin v. Howmedica Osteonics Corp.** — "Plaintiff has therefore not met his burden of showing that exceptional circumstances exist that counsel against transfer to the contractually selected forum." *Griffin v. Howmedica Osteonics Corp., No. 25-CV-302-JFJ (N.D. Okla. Oct. 2, 2025).* <https://www.courtlistener.com/docket/70562720/21/griffin-v-howmedica-osteonics-corporation/#:~:text=Plaintiff%20has%20therefore%20not%20met,to%20the%20contractually%20selected%20forum.>
+
+[^griffin-forum-selection]: **GableGotwals — Restrictive Covenants for Oklahoma Employees: Lessons from Griffin v. Stryker** — "The court acknowledged Oklahoma’s strong policy against non-competes and said if the case stayed in Oklahoma, it would ‘likely’ find the non‑competition/non‑solicitation provisions void. Nevertheless, it concluded that Oklahoma’s policy interest did not constitute the type of ‘exceptional circumstance’ needed to override the parties’ mandatory Michigan forum selection, and it also referenced judicial interests against forum shopping and a race to the courthouse." *GableGotwals, Restrictive Covenants for Oklahoma Employees: Lessons from Griffin v. Stryker (Feb. 26, 2026).* <https://www.gablelaw.com/restrictive-covenants-for-oklahoma-employees-lessons-from-griffin-v-stryker/>
+
+[^sb1543-enrolled]: **Enrolled Senate Bill 1543 (2024)** — "A person who makes an agreement with an employer, whether in writing or verbally, not to compete with the employer after the employment relationship has been terminated, shall be permitted to engage in the same business as that conducted by the former employer or in a similar business as that conducted by the former employer as long as the former employee does not directly solicit, directly or indirectly, actively or inactively, the sale of goods, services or a combination of goods and services from the established customers or independent contractors of the former employer." *Enrolled S.B. 1543, 59th Leg., 2d Reg. Sess. (Okla. 2024) (vetoed).* <https://www.oklegislature.gov/cf_pdf/2023-24%20ENR/SB/SB1543%20ENR.PDF>
+
+[^mcafeetaft-sb1543-veto]: **McAfee & Taft — Oklahoma Legislature Passes Bill Broadening Scope of Permissible Non-Solicitation Agreements** — "UPDATE: Oklahoma Governor Kevin Stitt vetoed this bill April 30, 2024, and the Legislature did not override the veto in the 2024 legislative session." *McAfee & Taft, Oklahoma Legislature Passes Bill Broadening Scope of Permissible Non-Solicitation Agreements (Apr. 2024).* <https://www.mcafeetaft.com/oklahoma-legislature-passes-bill-broadening-scope-of-permissible-non-solicitation-agreements/>