Chance Combs and Preston Long v. Elite Title Company, Inc.

2022 Ark. App. 231, 646 S.W.3d 230
CourtCourt of Appeals of Arkansas
DecidedMay 18, 2022
StatusPublished

This text of 2022 Ark. App. 231 (Chance Combs and Preston Long v. Elite Title Company, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Chance Combs and Preston Long v. Elite Title Company, Inc., 2022 Ark. App. 231, 646 S.W.3d 230 (Ark. Ct. App. 2022).

Opinion

Cite as 2022 Ark. App. 231 ARKANSAS COURT OF APPEALS DIVISION II No. CV-21-258

CHANCE COMBS AND PRESTON Opinion Delivered May 18, 2022 LONG APPELLANTS APPEAL FROM THE WASHINGTON COUNTY CIRCUIT COURT [NO. 72CV-21-671] V.

HONORABLE DOUG MARTIN, ELITE TITLE COMPANY, INC. JUDGE APPELLEE AFFIRMED

RAYMOND R. ABRAMSON, Judge

This is an interlocutory appeal of an amended preliminary injunction enjoining

appellants Chance Combs and Preston Long from conducting similar business as their

former employer, appellee Elite Title Company (“Elite”).1 Appellants assert that we should

apply common-law principles because the parties’ agreement predated the relevant 2015

statute and should thereby find that the noncompete provision is unenforceable in its

entirety because (1) there is no valid protectable interest of the employer since the agreement

merely protects against ordinary competition; (2) the circuit court is prohibited from

enforcing the agreement other than as specifically written under common-law standards; and

1 Such an interlocutory order is specifically appealable pursuant to Ark. R. App. P.– Civil 2(a)(6) (2021), which provides for an interlocutory appeal of an order “by which an injunction is granted, continued, modified, refused, or dissolved[.]” (3) the covenant is overly broad geographically because it includes areas outside those of

Elite’s trade area. We disagree and affirm.

Elite is a title company that has been in business since 1994. It is headquartered in

Springdale with two other offices in Northwest Arkansas and a single office located in

Oklahoma. Elite was founded and is owned by Carla Burg. Elite is differentiated from other

title companies because of its trade secrets. One of Elite’s confidential trade secrets is its title

plant. The title plant is a proprietary-software program owned by Elite that indexes the first

deed that is filed of record in the county and goes forward to the present. It allows Elite to

conduct searches quickly and efficiently. Elite maintains it is one of its largest assets with a

seven-figure value.

Elite markets its title plant and the availability of those services to customers on its

website. Elite does not let other title companies use its title plant. Appellant Combs

admitted that the database containing the title plant could be considered a trade secret. Elite

requires employees to keep information about the title plant confidential, and they must

have a password to access the title plant. Elite’s pricing and customers are also Elite’s

confidential trade secrets.

Elite’s customer relationships are Elite’s property. Employees must log in with a

password to be able to access the customers’ files and paperwork. Elite has a policy and

procedure manual (“Manual”) that requires employees to keep Elite’s confidential

information and trade secrets confidential. The Manual includes instruction about

employees maintaining passwords.

2 Elite also requires employees to sign a confidentiality and noncompetition agreement

when they are hired to protect Elite and its confidential trade secrets. In March 2013, Elite

hired appellant Long to work as a closing coordinator, and he eventually became a closing

agent. Long was Ms. Burg’s stepson for many years. As part of his employment, Long entered

into a confidentiality and noncompetition agreement with Elite. Long had no prior

experience in the title business. All of his training in the title business and how to be a closing

agent was provided by Elite.

Long was later promoted to lead the closing team as head of the closing department.

Elite paid Long an $80,000 salary and also paid for his house and truck. Long had

responsibility and signature authority over the escrow account, which is the biggest account

at any title company. Elite maintains that Long was in a position of authority and trust as

head of the closing department.

In April 2015, Elite hired appellant Combs to serve as in-house legal counsel after he

had graduated from law school. After failing the bar exam, Elite trained Combs in the title

department and helped him obtain his title-agent license. A year later, Combs passed the bar

exam and became Elite’s in-house counsel in addition to being a title agent. As part of his

employment, Combs entered into a confidentiality and noncompetition agreement with

Elite. Combs had no prior experience working in the title business. Elite provided Combs

all his training, including how to work for a title company, performing closings, and drafting

deeds. Long was Combs’s immediate supervisor.

3 Combs also managed Elite’s 1031 transactions.2 Twenty years ago, Elite formed Like-

Kind Exchange, LLC (“Like-Kind”), to handle 1031 exchanges for Elite’s customers. Like-

Kind generates fees of a few hundred dollars per transaction for acting as the qualified

intermediary during the 1031 exchange and then Like-Kind pays the fee to Elite’s operating

account. As Elite’s general counsel, Combs was appointed manager of Like-Kind to handle

customers’ 1031 transactions. Combs was given signature authorization for the Like-Kind

bank account.

Combs and Long each were head of their departments and had significant knowledge

of all of Elite’s trade secrets and how Elite is run. They had access to Elite’s title plant and

pricing. Appellants had to log in with a password to be able to access the customers’ files and

paperwork.

Both appellants agreed to sign and did sign the confidentiality and noncompetition

agreements (“Agreements”), which prohibit employees of Elite from working for a direct

competitor of Elite and/or soliciting current and former customers of Elite during their

employment and for a period of two years after their employment ends. The Agreements

also prohibit using or disclosing Elite’s confidential information and trade secrets. Section

4(b) of the Agreements contains a severability clause. The Agreements are geographically

limited to the counties surrounding Elite’s offices in Washington County and Benton

County and the office located in Oklahoma.

2 A 1031 exchange is a real estate investing tool that allows investors to exchange one investment property for another and defer capital gains or losses.

4 On January 11, 2021, appellants resigned, but they offered to remain on staff for an

additional two weeks if Ms. Burg would continue paying them their $80,000 salaries and pay

each of them an additional $10,000. Ms. Burg declined their offer. Shortly thereafter, Elite

discovered appellants were working for a competitor called Apex Title in Rogers, Arkansas.

Apex Title was located only in Oklahoma, but it opened a Rogers location around October

8, 2020. Combs had a 10 percent ownership interest in the Apex Rogers location, and Long

had a 30 percent ownership interest.

Long testified that he began discussions with Apex about going to work for the

company in the late summer of 2020. After appellants resigned from Elite, significant Elite

business was being transferred to Apex Title. Elite also discovered that on October 1, 2020,

Combs had created a separate 1031 exchange company called 1031 Intermediary Services,

LLC––while he was still employed by Elite as its general counsel. Also while still employed

as general counsel, Combs used the new company for at least three transactions instead of

using Like-Kind. Elite alleges that through these 1031 transactions, Combs stole

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Bluebook (online)
2022 Ark. App. 231, 646 S.W.3d 230, Counsel Stack Legal Research, https://law.counselstack.com/opinion/chance-combs-and-preston-long-v-elite-title-company-inc-arkctapp-2022.