274 Ill. App. 3d 811 - Abel v. Fox’s Empirical Analysis
1995
Citation profile
4 federal appellate · 19 state decisions
How this case has been cited
Cited by 44 later decisions — most recently February 2015 · most notably 292 Ill. App. 3d 131 - Lawrence & Allen, Inc. v. Cambridge Human Res. Group, Inc. (1997), 339 Ill. App. 3d 1021 - Health Professionals, Ltd. v. Johnson (2003)
4 federal appellate · 19 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on 8 Ill. 2d 351 - Bauer v. Sawyer · 207 Ill. App. 3d 736 - Millard Maintenance Service Co. v. Bernero · Hopper v. All Pet Animal Clinic, Inc. · 250 Ill. App. 3d 922 - Springfield Rare Coin Galleries, Inc. v. Mileham · More v. Bennett
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 44 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“To be enforceable, a covenant not to compete must be ancillary to either a transaction (an otherwise valid contract), or a valid relationship. * * * Therefore, a noncompetition covenant entered into by an at-will employee, whether the employee is employed under a written or oral agreement, complies with the requirement of ancillarity.”
2 later decisions quote this exact passage · from the majority““We read Creative Entertainment *** to stand for the proposition [that] a covenant not to compete signed by an at-will employee employed under an oral agreement cannot be ancillary to an employment agreement, because an at-will employee employed under an oral agreement does not have an otherwise “valid employment contract.’ ” Abel, 274 Ill. App. 3d at 816 .”
1 later decision quote this exact passage · from the majority““(2) Promises imposing restraints that are ancillary to a valid transaction or relationship include the following: (b) a promise by an employee or other agent not to compete with his employer or other principal.” (Emphasis added.) Restatement (Second) of Contracts § 188(2)(b), at 41 (1981).”
1 later decision quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.