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

Today the Federal Trade Commission voted 3-2 to approve a Final Rule that, absent a successful legal challenge, will ban most noncompete agreements in the United States beginning 120 days after publication in the Federal Register.

Key provisions in the Final Rule are as follows:

  • New noncompetes
    • Banned for all workers, including “senior executives,” following