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Holstein v. Collins

Federal CircuitJanuary 30, 2026No. 23-1451
DismissedLico, Inc.
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Case Details

Status — whether other courts must follow this ruling
Published
Procedural Posture — the stage the case had reached
appeal

Related Laws

No specific laws identified for this ruling.

Outcome

The appeal was dismissed as moot because the non-compete agreement at issue expired by its own terms (two years after the employee's July 3, 2017 resignation) before the court could issue a ruling with legal effect.

What This Ruling Means

**Holstein v. Collins: Non-Compete Agreement Expires During Legal Fight** This case involved a dispute over a non-compete agreement between an employee named Holstein and their former employer, Lico, Inc. Holstein had resigned from the company on July 3, 2017, and was subject to a non-compete clause that prevented them from working for competitors or starting a competing business for two years after leaving. The court dismissed the entire appeal without making any decision on the merits of the case. The reason was simple timing: by the time the court was ready to issue its ruling, Holstein's two-year non-compete period had already expired on its own in July 2019. Since the restriction was no longer in effect, the court determined there was no point in deciding whether the agreement was valid or enforceable. **What This Means for Workers:** This case shows that sometimes the best defense against a non-compete agreement is simply waiting it out. Many non-compete clauses have time limits, and if legal challenges drag on long enough, the restrictions may expire naturally. Workers facing non-compete disputes should consider the timeline carefully and remember that these agreements don't last forever. However, this doesn't resolve questions about whether such agreements are enforceable in the first place.

This summary was generated to explain the ruling in plain English and is not legal advice.

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