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ADP, LLC v. Eric Manchir

Tenn. Ct. App.November 8, 2017No. M2016-02541-COA-R3-CV
Plaintiff WinADP, LLC
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Case Details

Judge(s)
Chief Judge D. Michael Swiney
Status — whether other courts must follow this ruling
Published
Procedural Posture — the stage the case had reached
Summary judgment granted by trial court; affirmed on appeal

Related Laws

No specific laws identified for this ruling.

Claim Types

Breach of Contract

Outcome

ADP won summary judgment against Eric Manchir for breach of a non-competition restrictive covenant agreement. The court enforced the 12-month non-compete clause and awarded ADP specific performance plus attorney's fees and costs.

Excerpt

This appeal concerns an employment-related restrictive covenant. Eric Manchir ("Manchir") worked as a sales manager for ADP, LLC ("ADP"), a company that deals in human resources and business outsourcing matters. As a prerequisite to obtaining restricted stock options from ADP, Manchir consented to a restrictive covenant agreement ("the Agreement"). The Agreement contained, among other things, a non-competition clause extending to twelve months after Manchir left ADP. New Jersey law governs the Agreement. Manchir later resigned from ADP and went to work for an ADP competitor, Paycor, Inc. ("Paycor"). ADP sued Manchir in the Chancery Court for Davidson County ("the Trial Court") for breach of contract and sought specific enforcement of the Agreement. ADP filed a motion for summary judgment, which the Trial Court granted. The Trial Court also awarded ADP, pursuant to a provision in the Agreement, attorney's fees and costs. Manchir appeals. We hold, inter alia, that the Agreement is reasonable and enforceable under New Jersey law, that Manchir breached the Agreement, and that specific performance is an appropriate remedy. We affirm the judgment of the Trial Court.

What This Ruling Means

**What Happened** Eric Manchir worked as a sales manager for ADP, a human resources company. To receive company stock options, he had to sign an agreement that included a non-compete clause. This clause prevented him from working for competitors for 12 months after leaving ADP. When Manchir left the company and apparently took a job that violated this restriction, ADP sued him to enforce the agreement. **What the Court Decided** The court ruled in favor of ADP. It enforced the 12-month non-compete agreement and ordered Manchir to comply with its terms. The court also required him to pay ADP's attorney fees and legal costs. Despite the ruling being listed as a "plaintiff win" in the case summary, the outcome details indicate ADP (the employer) actually won this case. **Why This Matters for Workers** This case shows that courts will enforce non-compete agreements when they're reasonable in scope and time. Workers should carefully read any agreements they sign to receive benefits like stock options, as these often come with restrictions on future employment. Non-compete clauses can limit where you can work after leaving a job, and violating them can result in costly legal consequences including paying the former employer's legal fees.

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

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This ruling information is sourced from public court records via CourtListener.com. Case outcomes, claim types, and summaries are extracted using AI analysis and may be incomplete or inaccurate. It is provided for informational and educational purposes only and does not constitute legal advice.

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