HomeMy WebLinkAbout01-6560 EquityINVESTIGATIVE CONSULTANT
SERVICES, INC.,
Plaintiff
VS.
ALBERT R. THOMAS, SHERI
THOMAS and HAYES, STOUDT
& ASSOCIATES, INC.,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
01-6560 EQUITY
CIVIL ACTION - EQUITY
PLAINTIFF' S MOTION FOR PRELIMINARY INJUNCTION
BEFORE HESS, J.
OPINION AND DECREE NISI
In this case, the plaintiff, Investigative Consultant Services, Inc., has filed a complaint in
equity against the defendants and has, in that connection, filed a motion for preliminary
injunction. A hearing on the motion for preliminary injunction was held on December 19, 2001.
For the reasons which follow, the motion will be denied.
The plaintiff seeks to enjoin the defendants from contacting any of its clients or
customers or divulging trade secrets of the plaintiff. At the hearing, the plaintiff limited its
request for preliminary injunction to the defendant, Albert R. Thomas.
Mr. Thomas had worked for Investigative Consultant Services, Inc., (hereinafter ICS) for
approximately fifteen years as, first, an investigator, then a regional director and director of
investigations. On December 1, 1995, many years after he had been first hired, Mr. Thomas was
asked by ICS and, specifically, its president, Carl Schleigher, to sign an employment agreement.
The employment agreement stated, in pertinent parts, as follows:
12. (a) I understand and agree that, during the term
of my employment with ICS and within two (2)
years after termination of employment with ICS, I
01-6560 EQUITY
will not divulge the names or addresses of any of
the clients or customers of ICS to any party not
employed by ICS, nor will I call on or market any
current client of ICS on behalf of myself or any
other employer, with the exception that the identity
of clients or customers may be provided to future
clients as references. I agree that, ifI violate this
provision and perform services for any client of
ICS during said two (2) year period, either
personally or on behalf of a new employer, I will
pay ICS 100% of any fees paid by said client of
ICS as liquidated damages for the breach of this
provision ....
(c) I further agree, during the term of my
employment and for a period of two (2) years after
termination of my employment with ICS, not to
divulge any information which I learned while in
the employ of ICS which could be construed as a
"trade secret." All such disclosures must be
approved, in advance, by ICS' Chief Executive
Officer.
It is clear that signing the employment agreement was not voluntary and that employees who
refused to sign the agreement would be fired.
Mr. Thomas voluntarily terminated his employment with ICS on October 30, 2000, and
became associated with defendant Hayes, Stoudt & Associates, Inc., a competitor oflCS.
Thereafter, he contacted four clients of the plaintiff. He has not received any business from three
of the four clients contacted. He has, however, received some business from Travelers
Investigative Services which is owned by Aetna Insurance.
The standards for the issuance of a preliminary injunction are well established. Such an
injunction may be granted only if the plaintiff establishes that relief is necessary to prevent
immediate and irreparable harm which could not be compensated by damages; greater injury
would result by refusing the injunction than by granting it; the injunction will restore the parties
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01-6560 EQUITY
to their status as it existed immediately prior to the alleged wrongful conduct; and the activity
sought to be restrained is actionable and the injunction issued is reasonably suited to abate such
activity. Anchel v. Shea, 762 A.2d 346, 351 (Pa. Super. 2000). In addition, an injunction cannot
be granted unless the plaintiff establishes that the right to relief is clear. Id~.
In this case, we agree with the defendant that the plaintiff has failed to prove the
likelihood of success in enforcing its restrictive covenant. Non-compete covenants are
agreements in restraint of trade and, thus, are not favored by the courts. They are, accordingly,
narrowly construed. Jacobson & Co. v. International Environment Corp., 427 Pa. 439, 235 A.2d
612 (1967). In Pennsylvania, restrictive covenants are enforceable but only if they are incident
to an employment relationship between the parties, the restrictions imposed by the covenant are
reasonably necessary for the protection of the employee, and the restrictions imposed are
reasonably limited in duration and geographic extent. See Hess v. Gebhard & Co., Inc., 769
A.2d 1186, 1191 (Pa. Super. 2001) citing earlier cases. Important in the matter sub judice is the
principle that, when a restrictive covenant is not executed until after the employee has agreed to
the terms of employment and begun work, then the covenant may not be enforced absent new
consideration. See Davis & Warde, Inc. v. Tripodi, 420 Pa. Super. 450, 455, 616 A.2d 1384,
1387 (1992).
In the instant case, the testimony clearly indicates that the plaintiff operated its business
for some time without requiring employees to sign any employment agreements. At the time the
first agreement was signed by him, Mr. Thomas had worked for the plaintiff for many years. He
had become a regional director of investigations. His salary and compensation did not change in
exchange for signing the plaintiff' s agreement. Instead, he testified that at least one employee
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was fired for refusing to sign the agreement. Thus, the instant agreement lacks consideration and
is clearly unenforceable. ~
The plaintiff also argues that it is entitled to equitable relief because of the defendant's
misappropriation of trade secrets. In asserting an equitable right to protection against the misuse
of a trade secret, the burden is on the plaintiff to show that it held a trade secret and that the
defendant had misappropriated it in violation of a confidential relationship. Fidelity Fund, Inc. v.
DiSanto, 347 Pa. Super. 112, 121,500 A.2d 431,436 (1985). We agree with the defendant that
neither the names of insurance companies, pricing agreements, nor reporting methods are
confidential material in the investigative industry. The pricing arrangements which are dictated
by the companies who refer work leave little, if any, room for negotiation. The names of the
insurance companies and their structure is well known in the investigative industry and
investigative work and techniques are not unique to the plaintiff.
For all of the foregoing reasons, we will enter the following decree nisi.
DECREE NISI
AND NOW, this day of January, 2002, following hearing thereon, the
motion of the plaintiff for preliminary injunction is DENIED.
BY THE COURT,
Kevin A. Hess, J.
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Furthermore, it is well settled that an injunction is only available if the party seeking relief has no adequate remedy
at law. Worldwide Auditing Services, Inc. v. Richter, 402 Pa. Super. 584, 586, 587 A.2d 772, 774 n. 1 (1991). The
employment agreement here provides for the payment of 100% of any fees paid by a client as liquidated damages.
By its very terms, the agreement provides for an adequate legal remedy.
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01-6560 EQUITY
Theodore Adler, Esquire
For the Plaintiff
Douglas Miller, Esquire
For the Defendants
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INVESTIGATIVE CONSULTANT
SERVICES, INC.,
Plaintiff
VS.
ALBERT R. THOMAS, SHERI
THOMAS and HAYES, STOUDT
& ASSOCIATES, INC.,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
01-6560 EQUITY
CIVIL ACTION - EQUITY
IN RE: PLAINTIFF'S MOTION FOR PRELIMINARY INJUNCTION
BEFORE HESS, J.
DECREE NISI
AND NOW, this day of January, 2002, following hearing thereon, the
motion of the plaintiff for preliminary injunction is DENIED.
BY THE COURT,
Theodore Adler, Esquire
For the Plaintiff
Douglas Miller, Esquire
For the Defendants
Kevin A. Hess, J.
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