Short answerIn Pennsylvania, a non-compete clause is enforceable only if reasonable in scope, duration, and geography. In the 2 Pennsylvania rulings we track, the covenant was enforced in 2. Common-law reasonableness test (most physician/APRN/PA covenants barred as of 2025).
Based on 2 verified holdings from court opinions and regulatory actions, here is the breakdown for non-compete clauses in Pennsylvania:
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Full rulings
Enforcedconfidence: medium
“The Dorman Non-Compete Agreement Is Enforceable”
Covenant language at issue“the manufacture, distribution or sale of automotive replacement parts or general merchandise hardware of the kind or type sold by Dorman Products at the time of [Cardello’s] termination or to be released by Dorman Products within one year following [Cardello’s] termination.”
View the source opinion ↗ Dorman Products, Inc. v. Todd Cardello
Informational only — not legal advice. Enforceability is fact-specific; consult licensed counsel before acting.
Enforcedconfidence: medium
“At this stage of the litigation, I do not find the term to be unreasonable.”
Covenant language at issue“Employee expressly covenants and agrees that upon the termination of his or her employment hereunder . . . Employee will not for a period of eighteen (18) months . . . Manage, render, or perform services to or for any person or entity which is engaged in a business competitive to that of Greenway wi…”
View the source opinion ↗ Greenway Logistics v. White
Informational only — not legal advice. Enforceability is fact-specific; consult licensed counsel before acting.
Academic baseline · Bishara/Johnson
NCA Enforceability Index
7.1/10
as of 2014
Higher = historically more enforcer-friendly. Peer-reviewed 7-dimension framework (Harvard Dataverse DOI 10.7910/DVN/37A0L2):
- Statutory Basis: 5.0/10 — Explicit NCA statute → more enforcer-friendly
- Protectable Interests: 7.0/10 — How broadly courts define protectable interests
- Burden of Proof: 4.0/10 — Who must prove (un)reasonableness
- Consideration at Hire: 10.0/10 — Whether hiring alone validates an NCA signed at hire
- Consideration Post-Hire: 5.0/10 — Whether continued employment validates a mid-career NCA
- Blue-Pencil Doctrine: 8.0/10 — Whether courts can rewrite an overbroad clause
- Enforcement vs. Terminated: 4.0/10 — Whether NCAs bind fired employees, not just quitters
Historical context, not the current rule. This is the Bishara/Johnson academic
index through ~2014; many states have changed their non-compete statutes since. For the live picture, rely on
the verified rulings above — not this baseline. Informational only, not legal advice.
Disclaimer: This is an automated, informational early-warning signal derived from primary sources. It is NOT legal advice and creates no attorney-client relationship. Enforceability is fact- and jurisdiction-specific and changes over time; consult a licensed attorney before acting.
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