Murfreesboro Medical Clinic, P.A. v. Udom

Summary

The Tennessee Supreme Court considered whether a covenant not to compete between a physician and a private medical clinic was enforceable. The Court held that, except for restrictions specifically authorized by statute, physicians' covenants not to compete are unenforceable and void because they conflict with public policy concerning patient choice, continuity of care, and access to medical services. The Court reversed the Court of Appeals' judgment.

Holdings

1. Except for restrictions specifically prescribed by statute, covenants not to compete are unenforceable and void against physicians in Tennessee.
2. The covenant between MMC, a private medical clinic, and Dr. Udom was not within a statutory exception and therefore was unenforceable.

Questions Presented

1. Whether a covenant not to compete between a physician and a private medical clinic is enforceable under Tennessee law.
2. Whether Tennessee public policy and Tennessee Code Annotated section 63-6-204 permit enforcement of a physician's non-compete covenant outside the statutory circumstances.

Disposition

reversed