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States Create Patchwork of Noncompete Laws as Federal Ban Fails

Published
Score
12

Why it matters

Federal efforts to regulate noncompete agreements collapsed in 2025 after multiple court defeats, leaving employers to navigate a fractured state-by-state landscape. Florida enacted the CHOICE Act (effective July 1, 2025), which presumes noncompete enforceability and permits four-year restriction periods for covered employees. California maintains an absolute ban under Business and Professional Code § 16600.5 that applies regardless of where agreements were signed. Minnesota, North Dakota, Oklahoma, Washington, and Wyoming also ban most noncompetes, while Kansas joins Florida in presuming enforceability. The FTC, having abandoned its April 2024 Non-Compete Clause Rule, shifted to targeted enforcement—most recently issuing an order against Rollins, Inc. requiring it to stop enforcing noncompetes against 18,000+ employees and warning 13 other pest-control companies.

Courts have declined to apply choice-of-law provisions uniformly across state lines. In Centurion Service Group v. Wilensky, Delaware courts refused to enforce a Delaware choice-of-law clause, signaling that contractual forum selection may not resolve conflicts between state regimes. The enforceability of any given noncompete now depends on multiple overlapping factors: where the agreement was signed, where the employee worked, where they relocated, and which states' laws apply—a calculation that varies by jurisdiction and remains unsettled in many contexts.

Multistate employers face immediate compliance exposure. Companies must audit existing noncompete agreements against the laws of every state where employees work or may relocate. Agreements presumed enforceable in Florida may be void in California or Minnesota. The combination of state-level fragmentation and aggressive FTC enforcement targeting low-wage workers and information-scarce industries has made noncompete litigation increasingly unpredictable. Employers should prioritize reviewing choice-of-law provisions and considering whether noncompetes remain a viable retention tool given the regulatory uncertainty.

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