Summary
The District of Columbia Court of Appeals reviewed a preliminary injunction enforcing noncompete and noninterference provisions in a religious minister’s employment contract. The court held that civil courts had subject-matter jurisdiction because the dispute could be resolved through neutral principles of contract law and formally adopted equitable reformation for restrictive covenants. It vacated the injunction because the trial court’s revision impermissibly expanded the contractual restrictions and remanded for further proceedings, including whether any remaining provisions could be enforced against the minister’s wife.
Court
District of Columbia Court of Appeals
Jurisdiction
District of Columbia
Decision date
February 1, 2018
Docket number
Nos. 14-CV-1427 & 15-CV-1203
Disposition
vacated
Questions Presented
- Whether the District of Columbia courts had subject-matter jurisdiction to enforce the employment contract and preliminary injunction without impermissibly adjudicating ecclesiastical matters.
- Whether the District of Columbia should adopt the doctrine of equitable reformation for overbroad restrictive covenants.
- Whether the trial court exceeded the permissible scope of equitable reformation by modifying the noncompete clause to prohibit activities undertaken by the Steiners in their personal capacities.
- Whether the noninterference provision in the modified preliminary injunction was sufficiently definite and enforceable.
- Whether the preliminary injunction properly could bind Rivky Steiner, who claimed she was not a party to the employment contract.
Holdings
- Civil courts have subject-matter jurisdiction to enforce the employment contract and injunction because the dispute can be resolved through neutral principles of contract law without deciding matters of religious doctrine, polity, hierarchy, or governance.
- The District of Columbia adopts the doctrine of equitable reformation, allowing a court in appropriate circumstances to enforce the reasonable portion of an overbroad restrictive covenant even when the restriction is not mechanically severable under the blue-pencil rule.
- The trial court exceeded the permissible scope of equitable reformation by modifying the noncompete clause to prohibit the Steiners from engaging in religious outreach activities in their personal capacities.
- The record did not make clear what conduct the noninterference provision prohibited, and the trial court must clarify its intended meaning and determine whether it is enforceable under applicable reasonableness requirements.
- The trial court must determine on remand whether Rivky Steiner, who asserted that she was not a party to the contract, satisfies the prerequisites for any preliminary injunction that remains in force.
Court Document
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