BATON ROUGE (LN) — U.S. District Judge Shelly D. Dick voided a nationwide non-compete clause in an employment agreement between a Louisiana resident veterinarian and MedVet Associates, LLC, ruling that the restriction violates Louisiana’s strong public policy against restrictive covenants and cannot be reformed.
Dick granted partial summary judgment for plaintiff Jon M. Fletcher, a Louisiana resident who worked remotely from his home in East Baton Rouge Parish, and denied MedVet’s motion for summary judgment. The ruling effectively nullifies the employment agreement’s non-compete and non-solicitation provisions, which had defined the restricted territory as “North America.”
The dispute centered on whether Ohio law or Louisiana law governed the agreement. MedVet, an Ohio-based company, pointed to an Ohio choice-of-law clause and argued that Fletcher’s work primarily benefited its Ohio operations, where it employs more interns and residents than in any other state. Fletcher, who resigned on January 30, 2026, argued that he was a Louisiana resident, paid Louisiana payroll taxes, and performed his duties from Louisiana, making Louisiana law applicable.
Dick applied Louisiana’s choice-of-law principles, noting that under Louisiana Civil Code Article 3540, a choice-of-law clause is unenforceable if it contravenes Louisiana’s public policy. The court found that enforcing Ohio law, which permits broader non-compete restrictions, would significantly impair Louisiana’s policy of protecting employees’ common right to work.
“Louisiana has long had a strong public policy disfavoring” non-compete agreements, Dick wrote, citing Louisiana Revised Statute § 23:921. The statute requires that non-compete agreements specify the parishes or municipalities where the restriction applies. MedVet’s agreement, which defined the restricted area as “North America,” failed to meet this requirement.
MedVet argued that the court could reform the overbroad geographic restriction by striking out areas where it did not operate. However, Dick rejected this argument, noting that Louisiana courts have refused to reform non-competes that define geographic areas at a level significantly broader than parish or county. The court cited precedents voiding non-competes that covered the entire United States or entire states.
“The clause at issue here restricting Fletcher’s competition and solicitation in all of North America – an entire continent – is far broader than the nationwide and statewide clauses addressed above,” Dick wrote. “It clearly violates Louisiana law and is not subject to reformation.”
The court also ruled that MedVet’s forum selection clause, which required disputes to be litigated in Ohio, was unenforceable because Fletcher did not ratify it after the dispute arose, as required by Louisiana law.
Fletcher’s motion for a temporary restraining order and preliminary injunction was denied as moot because the underlying non-compete provisions were already void.