Xpo Logistics, Inc. v. Anis

2016 NCBC 52
CourtNorth Carolina Business Court
DecidedJuly 12, 2016
Docket16-CVS-10677
StatusPublished

This text of 2016 NCBC 52 (Xpo Logistics, Inc. v. Anis) is published on Counsel Stack Legal Research, covering North Carolina Business Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Xpo Logistics, Inc. v. Anis, 2016 NCBC 52 (N.C. Super. Ct. 2016).

Opinion

XPO Logistics, Inc. v. Anis, 2016 NCBC 52.

STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION COUNTY OF MECKLENBURG 16 CVS 10677

XPO LOGISTICS, INC., ) ) Plaintiff, ) ) v. ) ORDER ON MOTION FOR ) PRELIMINARY INJUNCTION FOUZI ANIS, ) ) Defendant. ) )

{1} THIS MATTER is before the Court on Plaintiff’s Motion for Preliminary Injunction (“Plaintiff’s Motion”), made pursuant to Rule 65 of the North Carolina Rules of Civil Procedure (“Rules”). For the reasons explained below, Plaintiff’s Motion is GRANTED. Robinson, Bradshaw & Hinson, P.A. by David C. Wright III, Douglas M. Jarrell, and Brian L. Church for Plaintiff. Alston & Bird LLP by Mark T. Calloway and Michael R. Hoernlein for Defendant. Gale, Chief Judge.

I. INTRODUCTION

{2} Plaintiff XPO Logistics, Inc. (“XPO”) seeks to enjoin Defendant Fouzi Anis (“Anis”), XPO’s former Director of Financial Planning and Analysis in XPO’s supply chain division (“Supply Chain”), from pursuing employment with Syncreon America Inc. (“Syncreon”) or its affiliates, and from otherwise using or disclosing XPO’s trade secrets or confidential information. XPO seeks to enforce an employment agreement (“Employment Agreement”) that includes restrictive covenants and that Anis signed following XPO’s acquisition of Anis’s initial employer, Landstar Supply Chain Solutions (“LSCS”), a subsidiary of Landstar System, Inc. (“Landstar”), by stock merger. {3} Plaintiff’s Motion presents a question of whether the Employment Agreement’s attempts to restrict competition and disclosure of confidential information are supported by valid consideration. Where, as here, the agreement is consummated after the initiation of the employment relationship, a covenant against competition must be supported by consideration other than the promise of continued at-will employment. XPO contends, and Anis denies, that such consideration exists here based on either of two provisions in the Employment Agreement. First, the Employment Agreement provides that Anis would be entitled to severance payments if she is terminated without cause. Anis contends that the promise of such payments is illusory, because the possible severance payment is conditioned on her providing a release of claims that must be acceptable in XPO’s sole discretion. Second, the Employment Agreement includes an arbitration clause that attempts to require any claims made by Anis to be submitted to arbitration in North Carolina. Anis contends that this provision was never intended as reciprocal consideration for the Employment Agreement, and that, in any event, the arbitration clause is so one-sided in favor of XPO that it cannot legitimately qualify as consideration for the covenant restricting Anis’s right to compete with XPO. {4} The Court concludes that the promise for potential severance payments is not illusory and therefore provides consideration for the restrictive covenants that XPO seeks to enforce. The Court further concludes that it is unlikely that XPO will be able to prove that the arbitration provision provides consideration for the restrictive covenants. While Anis vigorously contests the validity of the covenant against competition, she has not yet challenged her obligation to honor the confidentiality obligations of the Employment Agreement or XPO’s assertion that the information in her possession constitutes protectable trade secrets. II. PROCEDURAL BACKGROUND

{5} XPO filed its Complaint on June 15, 2016, asserting claims for breach of contract, violation of the North Carolina Trade Secrets Protection Act, and conversion, and requesting issuance of a temporary restraining order and preliminary and permanent injunctive relief. {6} On June 17, 2016, after a hearing during which the parties presented evidence and legal arguments, Judge Robert T. Sumner granted XPO’s motion for a temporary restraining order (“TRO”) and entered a TRO prohibiting Anis from violating her noncompetition restriction and from using or disclosing XPO’s trade secrets and confidential information. {7} On June 23, 2016, Chief Justice Mark Martin of the North Carolina Supreme Court designated this matter as a complex business case. On June 24, 2016, this Court issued a Consent Order Continuing Temporary Restraining Order, which provided that the TRO shall remain in effect until the Court rules on Plaintiff’s Motion. The parties submitted briefs and other supporting material. The Court heard argument on Plaintiff’s Motion on June 29, 2016. The parties requested that the Court refrain from ruling for a brief period to allow them to discuss the possibility of an agreed-upon resolution. On July 7, 2016, the parties advised that they could not reach agreement and that the Court should proceed with its determination. Plaintiff’s Motion is ripe for ruling.

III. FINDINGS OF FACT

{8} The Court makes the following findings of fact solely for the purpose of ruling on Plaintiff’s Motion, and without prejudice to the Court’s ability to make contrary findings upon subsequent proceedings. {9} XPO is a Delaware corporation with offices in Charlotte, North Carolina, and its corporate headquarters in Greenwich, Connecticut. XPO is a global-transportation and third-party-logistics provider. {10} XPO’s Supply Chain offers a variety of customized logistics solutions to its customers, including fulfillment, reverse logistics, factory support, manufacturing, packaging, transportation management, and supply-chain consulting. XPO’s services also include expedited shipping solutions for customers, which XPO has organized into three business functions: managed transportation, ground solutions, and air-charter solutions (the “Expedite Services”). Through its Supply Chain and Expedite Services divisions, XPO serves customers in multiple industries, including the automotive and technology industries. {11} Anis was initially employed by LSCS in June 2011 as LSCS’s Director of Accounting and was located in Southfield, Michigan. There is no evidence that Anis had any written employment agreement or covenant not to compete with LSCS or Landstar. XPO acquired LSCS’s stock in December 2013. Anis remained employed by XPO until June 3, 2016. Her most recent position with XPO was Director of Financial Planning and Analysis for Expedite Services, working within XPO’s Supply Chain. {12} In early 2014, Anis executed the Employment Agreement in connection with her employment at XPO. Section 17(a) of the Employment Agreement mandates that the agreement shall be governed by North Carolina law. {13} In the Employment Agreement, Anis promised not to use or disclose XPO’s confidential information (“Confidential Information”) except in the course of fulfilling her duties for XPO and to return all of XPO’s Confidential Information and other property, including all electronically stored information, to XPO by the last day of her employment. {14} Section 7 of the Employment Agreement also contains a covenant against competition, which provides that, for a period of six months after termination of her employment, Anis would not provide services that are the same as, or reasonably related to, the services she performed during her last two years at XPO. This covenant was limited to defined geographic areas and competing businesses. {15} Section 7(e) of the Employment Agreement provides as follows: Your Non-Compete Payments if We Terminate You Without Cause.

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Cite This Page — Counsel Stack

Bluebook (online)
2016 NCBC 52, Counsel Stack Legal Research, https://law.counselstack.com/opinion/xpo-logistics-inc-v-anis-ncbizct-2016.