LA Third Circuit denies enforcement to over-broad no solicitation agreement

The Louisiana Court of Appeals for the Third Circuit recently affirmed a trial court grant of summary judgment refusing to enforce a non-compete/customer solicitation agreement. The Court made it clear that the Third Circuit requires a geographic limitation on both the non-competition agreement as well as the no solicitation agreement. The Court found the agremement deficient "in two respects: it does not designate the parishes or municipalities in which Bledsoe is prohibited from soliciting customers, and it purports to prohibit him from soliciting potential customers." H. B. Rentals, LC, et al v. Maurice Bledsoe, Jr., CA 09-478 LA Ct App, 3rd Cir. 09-478 (La.App. 3 Cir. 11/04/09); 2009 La. App. LEXIS 1865.