On October 18, 2024, the Federal Trade Commission (“FTC”) gave notice that it would appeal a Texas federal court’s decision halting its non-compete rule (the “Rule”) from taking effect as to all employers nationwide. The appeal sets the stage for a decision by the conservative Fifth Circuit, which has become a key battleground for challenges

On April 23, 2024, the Federal Trade Commission (“FTC”) voted 3-2 to issue a proposed final rule (“Final Rule”), which, absent a successful legal challenge, will ban most noncompete agreements in the United States. 

Despite more than 26,000 comments from the public, the Final Rule does not narrow the rule first proposed by the FTC

As recently foreshadowed, the National Labor Relations Board (“NLRB” or “Board”) now appears poised to weigh in on whether noncompete agreements, even those that may be legal under state law, violate the National Labor Relations Act (“Act”).

Background: NLRB GC Targets Noncompetes

On May 31, 2023, Board General Counsel Jennifer Abruzzo issued a memorandum stating