NORTH AMERICAN SENIOR BENEFITS, LLC v. ALISHA WIMMER

CourtCourt of Appeals of Georgia
DecidedJune 13, 2023
DocketA23A0162
StatusPublished

This text of NORTH AMERICAN SENIOR BENEFITS, LLC v. ALISHA WIMMER (NORTH AMERICAN SENIOR BENEFITS, LLC v. ALISHA WIMMER) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
NORTH AMERICAN SENIOR BENEFITS, LLC v. ALISHA WIMMER, (Ga. Ct. App. 2023).

Opinion

FIFTH DIVISION MCFADDEN, P. J., BROWN and MARKLE, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

June 13, 2023

In the Court of Appeals of Georgia A23A0162. NORTH AMERICAN SENIOR BENEFITS, LLC v. WIMMER et al.

MCFADDEN, Presiding Judge.

This case calls upon us to construe Georgia’s Restrictive Covenants Act,

OCGA § 13-8-50 et seq. At issue is the enforceability of a restrictive covenant that

operates after the end of the parties’ business relationship, that undertakes to prohibit

solicitation of employees, but that lacks an explicit geographic limitation. We hold

that it is not enforceable.

Under the Act, “enforcement of contracts that restrict competition during the

term of a restrictive covenant, so long as such restrictions are reasonable in time,

geographic area, and scope of prohibited activities, shall be permitted.” OCGA §

13-8-53 (a). But “[a]ny restrictive covenant not in compliance with the provisions of this article is unlawful and is void and unenforceable” unless it can be cured under

the blue-pencil provisions. OCGA § 13-8-53 (d). Cf. OCGA § 13-8-56 (4) (setting out

a different rule for restrictions that operate during the term of a business relationship).

And, as detailed below, the restrictive covenant before us today cannot be so cured.

The Act sets out two exceptions to the requirement that restrictive covenants

that operate after the end of the parties’ business relationship must contain a

geographic limitation. Those exceptions apply to restrictions on efforts to solicit a

former “employer’s customers,” OCGA § 13-8-53 (b), and to trade secrets. OCGA §

13-8-53 (e). Subsections (b) and (e) go on to specify requirements the General

Assembly deemed appropriate for those types of restrictions.

The General Assembly did not set out an exception for restriction on

solicitation of a former employer’s employees. So it is not within our purview to

create one.

The restrictive covenant before us today prohibits Alisha and Ryan Wimmer

from soliciting employees of their former employer, North American Senior Benefits,

LLC (“NASB”). The Wimmers argue that it is unenforceable because it does not

contain an express geographic limitation in scope.

2 The state-wide business court found the restrictive covenant to be

unenforceable as to the Wimmers’ conduct after the termination of their contracts. We

agree. We also hold that the court did not err in declining to modify the restrictive

covenant to make it enforceable. So we affirm.

We note that the state-wide business court “emphasize[d] that its ruling . . .

only applie[d] to the [n]on-[s]olicitation [p]rovision’s validity and enforceability ‘post

association’ and [was] in no way to be construed as a ruling on the [n]on-[s]olicitation

[p]rovision’s enforceability related to [d]efendants’ conduct prior to the termination

of the Wimmers’ . . . [c]ontracts.” . That fact merits emphasis because the Act

distinguishes “contracts that restrict competition after the term of employment” from

those that operate during the term of employment. See OCGA § 13-8-53 (a).

Likewise, our opinion today addresses the enforceability of the covenant only insofar

as it applies to post-association conduct.

1. Facts and proceedings below.

NASB is an independent marketing organization that operates in the insurance

field. The Wimmers entered contracts with NASB to serve as insurance agents. The

contracts contained non-solicitation-of-employees restrictive covenants that

prevented the Wimmers, during the terms of their contracts and for two years after

3 termination, from employing any employee of NASB. The Wimmers terminated their

contracts in June 2021, and at some point, formed Freedom & Faith, Inc., which

operates in the same industry as NASB.

NASB filed suit against the Wimmers and Freedom & Faith, asserting claims

for tortious interference with contractual and business relations; breach of contract;

and breach of the covenant of good faith and fair dealing. The defendants answered

the complaint and asserted class action counterclaims, alleging breach of contract,

fraud, and negligent misrepresentation, and seeking a declaration that the non-

solicitation-of-employees restrictive covenant is invalid and unenforceable. The

defendants filed a motion for declaratory relief, or in the alternative, for judgment on

the pleadings.

After a hearing, the state-wide business court found that the non-solicitation-

of-employees restrictive covenant was void and unenforceable as applied to the

Wimmers’ conduct after the termination of their relationship with NASB because the

covenant contains no territorial restraint whatsoever. The court then held that

modifying or “blue-penciling” the provision to repair the deficiency would materially

alter the provision. So the court granted the defendants’ motion for declaratory relief

in part, as it related to the covenant’s enforceability regarding the Wimmers’ conduct

4 that occurred after the termination of their contracts. The court also permanently

enjoined NASB from attempting to enforce the covenant as to post-termination

conduct.

The court then granted the defendants’ motion for judgment on the pleadings

on NASB’s claims for tortious interference with contractual and business relations,

breach of contract, and breach of the covenant of good faith and fair dealing to the

extent those claims were based on alleged covenant violations that occurred after the

Wimmers had terminated their contracts with NASB. NASB filed this appeal.

2. The non-solicitation-of-employees restrictive covenant is unenforceable as

to the Wimmers’ conduct after termination of their contracts.

The parties agree that the restrictive covenant before us is governed by

Georgia’s Restrictive Covenants Act, OCGA § 13-8-50 et seq. The Act applies to

“contracts and agreements between or among . . . [e]mployers and employees[.]”

OCGA § 13-8-52 (a) (1). And although the parties’ contracts designate the Wimmers

as independent contractors, the Act defines “employee” to include independent

contractors. OCGA § 13-8-51 (5) (C). See also Belt Power v. Reed, 354 Ga. App. 289,

293-294 (2) (a) (840 SE2d 765) (2020) (restrictive covenants prohibiting former

employees from soliciting or hiring their former employer’s employees “fall within

5 the scope of the Restrictive Covenants Act, and the enforceability of those covenants

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NORTH AMERICAN SENIOR BENEFITS, LLC v. ALISHA WIMMER, Counsel Stack Legal Research, https://law.counselstack.com/opinion/north-american-senior-benefits-llc-v-alisha-wimmer-gactapp-2023.