Gallagher Benefit Services, Inc. v. Richardson

CourtDistrict Court, E.D. Texas
DecidedMarch 24, 2020
Docket6:19-cv-00427
StatusUnknown

This text of Gallagher Benefit Services, Inc. v. Richardson (Gallagher Benefit Services, Inc. v. Richardson) is published on Counsel Stack Legal Research, covering District Court, E.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gallagher Benefit Services, Inc. v. Richardson, (E.D. Tex. 2020).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS No. 6:19-cv-00427 Gallagher Benefit Services, Inc. et al., Plaintiffs, V. Ellen Richardson, Defendant. Before BARKER, District Judge ORDER Plaintiffs, referred to collectively as “Gallagher,” accuse defendant Ellen Richardson of breaking the noncompete and nondisclosure clauses of her employment contract. Gallagher seeks a preliminary injunction that blocks Richardson from competing in certain ways. For the reasons set forth below, that request is granted in part and denied in part. Background Ellen Richardson worked as an insurance consultant for Arthur J. Gallagher & Co. and its subsidiary, Gallagher Bene- fit Services, Inc. Gallagher gave Richardson clients to service for the company, and Richardson in turn signed an employ- ment agreement that included a noncompete clause and a nondisclosure clause. The first clause required Richardson not to recruit or service any of her Gallagher clients for two years after she stopped working there. The second clause required Richardson not to disclose or use confidential Gallagher infor- mation after she stopped working there. In August 2019, Gallagher ended Richardson’s employ- ment. A few months later, Gallagher sued Richardson, alleg- ing that she went to work for a competitor and (1) misappro- priated Gallagher trade secrets, in violation of federal law; (2) kept and used Gallagher records in violation of the

nondisclosure clause by emailing herself a “producer report” containing names and contact information for Gallagher cli- ents; and (3) violated the noncompete clause by soliciting business from and servicing Gallagher’s former clients. Rich- ardson does not dispute that she emailed herself the producer report or that she is now servicing over 60 former Gallagher clients. Richardson does dispute whether the clauses are en- forceable, as well as Gallagher’s other allegations. Gallagher moved for a preliminary injunction that would (1) prohibit Richardson, until two years after her termination, from soliciting business from and servicing former clients of hers at Gallagher; (2) prohibit Richardson from making use of Gallagher trade secrets and confidential information; and (3) require Richardson to return and destroy copies of the pro- ducer report and all other Gallagher proprietary information. Richardson opposes the motion. She also seeks a transfer of venue to the Western District of Louisiana. Although Rich- ardson lives in Texas (very close to the state line), Gallagher’s office was in Shreveport, Louisiana. And Richardson argues that the clients she services were also in Louisiana. The venue motion will be addressed by separate order. On January 27, 2020, the court held a hearing and received evidence on the preliminary-injunction motion. The court then invited supplemental briefing on two topics (see Doc. 28): • What amount of security, if any, should plaintiffs pro- vide to satisfy Federal Rule of Civil Procedure 65(c) in the event that plaintiffs prevail on their application for preliminary injunction? • What evidence is there, if any, to support plaintiffs’ ar- gument that defendant’s current clients would have stayed with plaintiffs had defendant not continued to provide services to those clients? Gallagher filed supplemental briefing that did not address the court’s first question—what bond Gallagher should post if it won a preliminary injunction. Instead of addressing how to secure Richardson against any loss from a wrongful injunc- tion, Gallagher addressed its own alleged loss. Doc. 45. Gal- lagher also argued that it need not show irreparable injury to get a preliminary injunction. Id. Gallagher did argue that, if irreparable injury were required, some unspecified percent- age of its former clients may have stayed with it through the current time and into the future (such that their lost revenue could be addressed by prospective relief). But Gallagher did not submit evidence on what percentage of its clients would have stayed if Richardson had abided by her agreement—in other words, what evidence showed the extent of its alleged irreparable injury. Richardson argued that, a preliminary injunction could wrongfully restrain Richardson from servicing her existing clients—requiring a bond insuring her against that harm. Richardson did not argue that any bond would be required for an injunction against her recruiting new clients or using the Gallagher producer report. Doc. 46. Richardson also ar- gued that the court could not draw the factual inference that the former Gallagher clients at issue would have stayed with Gallagher through the present, or would now return to Gal- lagher if Richardson could no longer service those clients. Richardson argued that such a conclusion requires evidence, not inference, given that the Gallagher employee in Shreve- port who could have serviced those clients quit his job there. Gallagher then moved to strike the affidavit that Richard- son attached to her supplemental briefing. The court finds that affidavit ultimately immaterial given the court’s resolu- tion of the preliminary-injunction motion. So Gallagher’s mo- tion to strike is denied as moot. Gallagher’s choice to move to strike a responsive affidavit when Gallagher’s own supple- mental briefing was not fully responsive to the court's order will bear on reasonableness of any fees sought in this matter. Analysis Gallagher wrongly argues that it need not show irrepara- ble injury at this stage. A preliminary injunction, as an exer- cise of the federal courts’ equitable power, is governed by the traditional principles of equity set forth by federal courts. See Grupo Mexicano de Desarrollo S.A. v. Alliance Bond Fund, Inc., 527 U.S. 308, 318-19 (1999). Those requirements for a prelimi- nary injunction are a matter of federal remedial power, not state law. See Charles Alan Wright et al., Federal Practice & Pro- cedure § 4513 (3d ed.) (“It seems reasonably clear that prelim- inary injunctions or temporary restraining orders may be is- sued in a diversity case in accordance with the terms of Rule 65 regardless of state practice, and further that federal law supplies the standards for their issuance.”). So even if a state court would not require proof of irrepa- rable injury at this stage, it remains one of the four showings that a moving party must make to obtain a preliminary in- junction in federal court. Those four showings, now well-es- tablished, are (1) a substantial likelihood of success on the merits, (2) a substantial threat of irreparable injury if the in- junction is denied, (3) that the threatened injury outweighs any potential injury to defendant if the injunction is granted, and (4) that granting the injunction will not disserve the pub- lic interest. Brock Services, L.L.C. v. Rogillio, 936 F.3d 290, 296 (5th Cir. 2019). The moving party carries the burden of per- suasion on all four factors. Gallagher has shown a substantial likelihood of success on its claims. Gallagher has also shown a sufficient risk of irrep- arable injury if Richardson is allowed to recruit current Gal- lagher clients or to keep and use the producer report. But Gal- lagher has not provided sufficient evidence to allow the court to find an injunction-meriting risk of irreparable injury from Richardson continuing to service her existing clients for the remainder of the two years following her termination. 1.

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Gallagher Benefit Services, Inc. v. Richardson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gallagher-benefit-services-inc-v-richardson-txed-2020.