Family Heritage Life Insurance Company of America v. Combined Insurance Company of America
The Third DCA affirmed a temporary injunction entered against two former Combined Insurance employees and their new employer, Family Heritage, based on breaches of confidentiality clauses and two-year non-solicitation covenants. The court held the section 542.335(1)(j) presumption of irreparable injury arose because Combined showed protected legitimate business interests (trade secrets, confidential information, specialized training, goodwill) that were violated, and that the injunction properly reached the new employer, a non-signatory, which had notice of and benefited from the breaches.
Key facts
- Two former Combined Insurance employees joined competitor Family Heritage Life Insurance and solicited Combined's agents in violation of two-year non-solicitation covenants and confidentiality clauses in their employment agreements.
- The trial court entered a temporary injunction against the former employees and Family Heritage (a non-signatory to the employment agreements) after Combined sent Family Heritage a cease-and-desist letter, yet Family Heritage continued to benefit from and compensated the former employees for recruiting Combined's agents.
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Why it matters
This opinion is useful for employers enforcing non-solicitation covenants, particularly in confirming that a temporary injunction can extend to a competitor employer that is not a party to the covenant when it has… — full analysis with a trial
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