C.H. Robinson Worldwide, Inc. v. Traffic Tech, Inc.

Summary

The Eighth Circuit affirmed summary judgment for Traffic Tech, Inc. and former C.H. Robinson employees in litigation concerning restrictive covenants and alleged tortious interference with contractual relations. Applying Minnesota law, the court held that the customer non-solicitation covenant was overly broad and unenforceable. The court also held that the district court did not abuse its discretion in denying C.H. Robinson’s motion to voluntarily dismiss its claims against one former employee and Traffic Tech.

Holdings

1. Section IV(C)(1) of the restrictive covenants was overbroad and unenforceable under Minnesota law because it extended beyond solicitation of customers with whom the employees worked and covered virtually any person or entity that had conducted or potentially could conduct business with C.H. Robinson, while also lacking a geographic limit.
2. Because the restrictive covenants were unenforceable against the employees, they could not provide a contract supporting C.H. Robinson's tortious-interference claim against Traffic Tech.
3. The district court did not abuse its discretion by denying C.H. Robinson's motion to voluntarily dismiss with prejudice its claims against Peacock and the related claim against Traffic Tech.

Questions Presented

1. Whether the customer non-solicitation restriction in the employees' employment agreements was enforceable under Minnesota law.
2. Whether the unenforceable restrictive covenant could support C.H. Robinson's tortious-interference claim against Traffic Tech.
3. Whether the district court abused its discretion by denying C.H. Robinson's motion to voluntarily dismiss with prejudice its claims against Peacock and the related claim against Traffic Tech.

Disposition

affirmed