Six months ago, in July 2025, we published a blog post providing a brief history of noncompete agreements in the United States; describing the current status of federal restrictions on noncompetes; and discussing the landscape of various state restrictions and bans of noncompetes.  We also published an accompanying 50-state survey map providing additional information about the then-existing landscape of state laws restricting noncompete agreements.

This post serves to provide updates on the status of both federal and state restrictions on noncompetes; the accompanying 50-state survey map has also been updated.

Noncompete agreements are widely used by employers to limit workers’ ability to compete with their former employer during or after employment.  Employers use these agreements in a heavy-handed effort to control and constrain employees’ freedom to pursue better employment elsewhere.  Studies have shown that noncompetes suppress wages, hamper innovation, and block entrepreneurs from starting new businesses.[1]  Noncompete agreements compound the power imbalances employees already face in relationships with their employers, and they exist only to protect employers. –

Even though an estimated 30 million workers—nearly one in five Americans—are subject to a noncompete, the opaque and legalistic nature of these agreements make it hard for workers to know how they operate and how they are enforced.  This blog post is intended to serve as a primer for workers and attorneys alike to better understand (1) the current status of federal restrictions on noncompetes, and (2) the landscape of various state restrictions and bans of noncompetes.

Current Status of Federal Restrictions of Noncompete Agreements

FTC’s 2024 Rule Banning Noncompetes

On April 23, 2024, the Federal Trade Commission (“FTC”) issued a final rule banning noncompetes nationwide.  Under the final rule, a “non-compete clause” was defined as a term or condition of employment that either “prohibits” a worker from, “penalizes” a worker for, or “functions to prevent” a worker from (A) seeking or accepting work in the United States with a different person where such work would begin after the conclusion of the employment that includes the term or condition; or (B) operating a business in the United States after the conclusion of the employment that includes the term or condition.  For more information about the FTC final rule, see (1) Explaining the FTC’s Proposed Rule to Ban Noncompetes Nationwide (January 12, 2023); (2) Potential Impact of the FTC’s Proposed Rule to Ban Noncompetes Nationwide (January 19, 2023); (3) Explaining the FTC’s New Rule Banning Noncompetes Nationwide (April 24, 2024).

The U.S. Chamber of Commerce intervened in the first major legal challenge to the FTC rule filed on May 9, 2024, arguing that the FTC did not have the authority to issue rules that define unlawful methods of competition.  See Ryan LLC v. FTC, No. 3:24-cv-00986-E (N.D. Tex.).  The district court, the Northern District of Texas, granted summary judgment for Ryan LLC, thereby prohibiting the FTC from enforcing the rule nationwide.  See Ryan LLC, 2024 WL 3879954 (N.D. Tex. Aug. 20, 2024).  During the Biden administration, the FTC, then-led by Chair Lina Khan,  appealed to the Fifth Circuit.

FTC and Noncompetes under the Trump Administration

When President Trump took office for his second term, he selected then-Commissioner Andrew Ferguson, a fellow Republican, to replace Chair Lina Khan (a Biden appointee) as Chair of the FTC.  About a month into his new role, Chair Ferguson shared with Fox Business that the FTC under his leadership would not prioritize broad, prescriptive regulations like the noncompete ban but instead would emphasize case-by-case enforcement of existing laws.  Such piecemeal enforcement is considerably slower, less efficient, and less effective than the carefully considered ban the FTC had enacted.  Such an approach also ignores the limited resources of the FTC, which is comprised of approximately 1,000 employees tasked with protecting consumers from unfair, deceptive, or fraudulent business practices and promoting competition by preventing anticompetitive mergers or other practices nationwide.

In September 2025, the FTC formally announced what now-Chair Ferguson had hinted in February: the FTC planned to pursue enforcement actions for noncompete violations industry-by-industry instead of implementing a nationwide ban.  Demonstrating the inefficiencies inherent in this approach, as well as the administration’s lack of a serious commitment to eradicating a pervasive, explicitly anticompetitive practice, under Chair Ferguson’s leadership of the FTC over the past year, the Agency has only reported two enforcement actions relating to noncompete agreements: one action ordering the country’s largest pet cremation business to stop enforcing noncompetes against its nearly 1,800 employees; and a second merely issuing warning letters to healthcare employers and staffing companies to review their employment agreements to ensure they are appropriately tailored and compliant with the law.  On September 5, 2025, the FTC, led by Republican Andrew N. Ferguson, formally abandoned its appeal to the Fifth Circuit, thereby ending its effort to impose a blanket nationwide prohibition.

What we expect next:  Given the FTC’s inefficient approach to enforcing existing restrictions on noncompetes nationwide under Chair Ferguson’s leadership, we anticipate seeing the trend of sparse enforcement actions continue in 2026.  The FTC hosted a Noncompete Workshop in January 2026, showcasing several panels discussing noncompetes and the policy considerations surrounding ongoing debate about restrictions of noncompetes; and the FTC welcomed the public to submit comments about the scope, prevalence, and effects of employer noncompete agreements.  But those actions, at this point, are mere gestures.  It remains to be seen what, if anything, the Agency will do substantively to protect workers from noncompete agreements.

Status of Federal Law Restricting Noncompetes

Given the Supreme Court’s recent Loper Bright decision ruling that an agency’s interpretation where the law is ambiguous is not entitled to deference, and given the political climate, it is unlikely that administrative rulemaking will be an effective path for escalating restrictions on noncompetes.  Another path to a nationwide ban, however, is for Congress to pass legislation restricting or banning noncompetes, but that is also unlikely in the present political climate.

In June 2025, Senators Murphy (D-Conn) and Young (R-Ind) re-introduced the Workforce Mobility Act along with Senators Cramer (R-ND) and Kaine (D-Va).  See S. 2031, 119th Cong. (2025) (previously introduced by Senators Murphy and Young in 2019, 2021, and 2023).  If passed, this law would largely ban the use of noncompete agreements nationwide, permitting them only for limited exceptions such as in the case of the dissolution of a partnership or sale of a business, or for senior executive officials with severance agreements, and clarifying that nothing would preclude parties from contracting to prevent disclosure of trade secrets.  The law would direct the FTC and Department of Labor to enforce the law, would empower State Attorneys General to enforce it at the state level, and would create a private right of action.  Importantly, the law’s ban would apply retroactively.

Given that the bill was introduced in June 2025 and that, other than it being referred to the Committee on Health, Education, Labor, and Pensions, no further action has been taken, the chances of this bill being passed soon are slim.

State Survey of Current Restrictions of Noncompete Agreements

With the FTC’s abandonment of its 2024 nationwide ban, states have stepped in to enact their own legislation curtailing noncompete agreements, as discussed further below.  This has created a fragmented, fast-changing legal landscape.

Over the past three plus years, more than 150 bills have been introduced in more than 35 states restricting noncompetes to at least some degree.  Many states have adopted an incremental approach, passing a bill every few years or so implementing further restrictions on noncompetes; while others, like California, adopted a comprehensive noncompete ban from the start.  Keeping up with the constantly-changing landscape of state noncompete law is a challenging task, and this blog is by no means intended to serve as a fifty-state survey of existing laws and pending bills [please see our fifty-state survey of existing laws and pending bills].  Instead, this blog describes a few of the categories of commonly-seen restrictions on noncompetes across the states.

This blog was originally published in July 2025.  In 2025, 13 states either enacted legislation impacting noncompete enforceability, or legislation those states had previously passed went into effect.

Based on the rapid proliferation of state legislation restricting noncompete agreements over the past few years, we expect more legislation in 2026 focused on specific professions, such as healthcare workers, veterinarians, and broadcast employees; as well as more legislation imposing restrictions on noncompetes based on wage thresholds.  While many states introduced bills restricting noncompetes in 2025 on any or all of these bases, nationwide, the bills that were successful in becoming law were almost exclusively those that restricted noncompetes for healthcare workers.

One surprising development in 2025: bucking the trend of state legislatures passing laws restricting noncompetes over the past few years, Florida passed the CHOICE Act (Fla. Stat. Ann. § 542.41 et seq. effective July 1, 2025), strengthening employer-side noncompete agreements for high-wage earners.  The new law applies to employees earning more than two times the annual wage in their county and permits noncompetes for up to four years, creates a presumption of enforceability, and provides for preliminary injunctions for violators.  In doing so, Florida has made it easier to enforce covered noncompetes, in part by shifting the burden to employees to demonstrate the agreement’s unenforceability.

Total Bans

The simplest type of noncompete restriction is a total ban.  Six states so far have instituted total bans (CA, MN, MT, ND, OK, WY), and several legislatures are considering them.

State Spotlight: California

California, which has effectively banned noncompetes for over 150 years, has the broadest noncompete ban.  Its statute broadly prohibits agreements that restrain California employees from engaging in any lawful profession, trade, or business, subject to very limited exceptions, mostly in the context of the sale of a business (Cal. Bus. & Prof. Code § 16600 – 16602.5, latest amendments effective January 1, 2024).  Even if one of the narrow exceptions applies, the scope of the restrictive agreement must be reasonable both in geographic scope and duration.

As of January 1, 2024, California’s amendments went into effect, providing that “any contract that is void under this chapter is unenforceable regardless of where and when the contract was signed.”  Cal. Bus. & Prof. Code § 16600.5.  More specifically, the 2024 amendment states that the employer or former employer may not attempt to enforce such void contracts “regardless of whether the contract was signed and the employment was maintained outside of California.”  The new law thereby invalidates noncompetition agreements or other restrictive covenants to enforce the agreements – even when employees entered into the agreements outside California in a state where the competition restrictions are lawful.

Likely passed in response to California employers’ attempts to continue to force employees to sign unenforceable noncompetes, the 2024 amendment also states that an employer that either enters into a contract with a void noncompete agreement or attempts to enforce such a void agreement, “commits a civil violation.”  Finally, it provides that employees, former employees, or prospective employees may bring private, civil actions for injunctive relief or actual damages, and be entitled to recover attorney fees and costs.  In other words, the new law has teeth: employees can sue their employers for damages if the employer tries to enforce a void noncompete.

Shortly after the new provisions took effect, an employee sued his employer for enforcing a noncompete provision, and the employer has defended against his suit by challenging the constitutionality of the new law. The employee sought to apply California law, which would have concluded that the noncompete was unenforceable even though it was signed in another state; and the employer sought to apply Massachusetts law.  The employer won: DraftKings Inc. v. Hermalyn, 118 F.4th 416 (1st Cir. Sept. 26, 2024).  The extent to which the 2024 amendments to the California noncompete ban will be widely enforceable against noncompetes signed in other jurisdictions remains to be seen.

Update since last post: since July 2025, California has passed an amendment to the California Health & Safety Code §§ 1190 et seq. (effective January 1, 2026), which explicitly voids noncompetes for management of physician or dental practices after being acquired by private equity groups or hedge funds.

State Spotlight: Minnesota

Minnesota law completely bans noncompetes.  (Minn. Stat. § 181.988, effective July 1, 2023).  The statute clarifies that “employee” includes “independent contractors,” but the noncompete ban does not restrict non-solicitation agreements, nondisclosure agreements, or agreements designed to protect trade secrets or confidential information.  Indeed, many state statutes banning or restricting noncompetes clarify that the noncompete ban/restrictions are not intended to ban or restrict non-solicitation agreements or other, specified, types of restrictive covenants.  [No updates since last blog post in July 2025.]

Wage Thresholds

One of the most common types of laws restricting noncompetes is one that imposes wage thresholds below which employees are protected from noncompetes.  Twelve states (CO; D.C.; IL; ME; MD; MA; NV; NH; OR; RI; VA; and WA) have some sort of wage threshold noncompete ban.

Defined Wage Threshold

Many states with wage threshold noncompete bans implement a defined wage threshold beyond which noncompetes are permitted, with restrictions such as reasonable time, geographic area, and scope, sometimes set by statute and sometimes set by caselaw.  Most states with wage threshold bans increase this defined threshold annually linked to inflation or other metrics; few states increase the defined threshold periodically.

State Spotlight: Oregon

For example, Oregon’s wage threshold law (RCW §§ 49.62.005 – .900), which went into effect on January 1, 2020, bans noncompetes for employees making less than $100,000 annually.  Further, Oregon’s law bans noncompetes for independent contractors unless their earnings from the party seeking enforcement exceed $250,000 annually.  The law, which is not retroactive, provides that these annual income figures are adjusted annually for inflation.  The wage threshold in 2025 is approximately $116,427.

Update since last post: since July 2025, Oregon enacted a new law (effective June 9, 2025) that voids noncompete agreements between medical licensees unless certain ownership conditions are met, and permits noncompetes for up to three years under limited conditions.  See Or. Rev. Stat. §§ 58.375 – .376 .

State Spotlight: Illinois

Meanwhile, Illinois’ wage threshold law (820 ILCS §§ 90/1 et seq.) went into effect on January 1, 2022 and bans noncompetes for workers who make less than $75,000 annually, with the threshold increasing at regular intervals (“This amount shall increase to $80,000 per year beginning on January 1, 2027, $85,000 per year beginning on January 1, 2032, and $90,000 per year beginning on January 1, 2037.”).

Update since last post: since July 2025, the Illinois legislature continues to consider two bills introduced in the 2025 legislative session, H.B. 1642 (which would raise the income threshold to $300,000), and H.B. 2561 (which would ban noncompetes for reproductive healthcare or maternity care professionals if it would be likely to reduce the availability of reproductive healthcare or maternity care).

Average Earnings Wage Threshold

Another approach to a wage threshold noncompete is to tie the threshold to average wages in the nation, state, or county, or some other metric in federal law.  The benefit of this method is that the wage threshold will increase along with federal, state, or local wages; the weakness is that state or nationwide minimum wages, and other statutorily-defined wage thresholds, are not typically increased at the same pace as inflation, and so the ban will meaningfully protect fewer and fewer workers over time.

State Spotlight: Virginia

Virginia’s wage threshold law (Va. Code § 40.1-28.7:8, amendment goes into effect July 1, 2025), bans noncompetes for “low-wage employees,” defined as employees whose average weekly earnings are less than the average weekly wage in Virginia, or those who are entitled to overtime compensation under 29 U.S.C. § 207.  In defining “low-wage employees” in this way, Virginia has tied the threshold for the noncompete ban to statewide wages and to federal law.

Update since last post: since July 2025, Virginia implemented S.B. 1218 (which had been passed at the time of the last post and went into effect on July 1, 2025), banning noncompetes for employees entitled to overtime under the Fair Labor Standards Act regardless of their weekly income.  The Virginia legislature is presently considering two new bills related to noncompetes: S. 128 (which would impose new restrictions on noncompetes for healthcare workers), and S.B. 170 (which would prohibit enforcement of noncompetes against employees discharged without severance).

State Spotlight: Rhode Island

Rhode Island’s wage threshold law (R.I. Gen. Laws §§ 28-59-1 – 3), which went into effect January 15, 2020, prohibits noncompetes for employees entitled to overtime under the Fair Labor Standards Act, as well as for low-wage employees whose earnings are less than 250% of the federal poverty level.  [No updates since last blog post in July 2025.]

Healthcare Industry Bans

The most common type of state law restricting noncompetes is a ban or restriction of noncompetes for certain, or all, healthcare professionals.  These are increasingly popular, as demonstrated by the dozens of proposed bills introduced in the past two years alone that would either introduce healthcare industry bans in states with no or few other statutory restrictions on noncompetes, or would expand the types of defined healthcare professionals benefiting from a noncompete ban.  Sixteen states currently have some type of noncompete ban or restriction benefitting healthcare professionals (AR, CT, DE, IN, IA, KY, LA, MD, MA, NH, NM, OR, PA, SD, TX).

Profession-Specific Bans

The more common type of healthcare industry noncompete ban is a total ban on certain types of healthcare professions, such as physicians, nurses, or other healthcare practitioners.

State Spotlight: Massachusetts

For example, Massachusetts broadly protects several categories of healthcare professionals from noncompetes: physicians (Mass. Gen. Laws Ann. 112 § 12X (1977)); nurses (Mass. Gen. Laws Ann. 112 § 74D (1983)); and psychologists (Mass. Gen. Laws Ann. 112 § 129B (Oct. 24, 2004)).  [No updates since last blog post in July 2025.]

State Spotlight: Indiana

Indiana limits its noncompete ban to primary care physicians (IC § 25-22.5-5,5-2.5, effective July 1, 2023).

Update since last post: since July 2025, Indiana enacted a new law (S.B. 475, passed March 6, 2025), IC § 25-22.5-5.5-2.3, effective July 1, 2025), which expands the existing primary care physician ban to include all physicians.  The Indiana legislature is currently considering a new bill, S.B. 132 (introduced January 5, 2026), which would ban noncompetes for employees earning less than $150,000.

Profession-Specific Wage Thresholds and Restrictions

Another common approach to healthcare industry restrictions on noncompetes is to either ban noncompetes for certain healthcare practitioners below a defined wage threshold (distinct from the general wage threshold ban discussed above in Part III.A), or to define in the statute the conditions a noncompete must meet in order to be enforceable for specified groups of healthcare practitioners.  Some states have passed laws that are a combination of these two approaches.

State Spotlight: District of Columbia

Instead of banning noncompetes broadly for all medical specialists, the District of Columbia implements a wage threshold ban specific to medical specialists.  Specifically, D.C. law bans noncompetes for medical specialists earning less than $250,000 annually as of October 1, 2022, with the annual threshold increasing annually beginning in 2024, as described in the statute (D.C. Code. § 32-581.01 – 32-581.05, effective September 1, 2022).  “Medical specialists” are defined as those who hold a license to practice medicine, are a physician, and have completed their medical residency.  In addition to a medical specialist-specific wage threshold ban, D.C. law bans noncompetes in general for workers earning less than $150,000 annually (also increasing on an annual basis as defined in the statute, and approximately $162,164 in 2026).

Beyond just banning noncompetes for medical specialists who earn less than the annual wage threshold defined in the statute, D.C. law provides that, for medical specialists who earn more than $250,000 annually (as of 2026, approximately $270,274, pursuant to the statutorily-defined annual wage threshold increase), for a noncompete to be enforceable, the agreement must specify the functional scope of the restriction “including what services, roles, industry, or competing entities the employee is restricted from performing work in or on behalf of,” geographical limitations, and must not exceed two years in duration, among other statutory requirements.  [Other than annual increases in the wage threshold, no updates since last blog post in July 2025.]

State Spotlight: Maryland

Like D.C., Maryland implements a healthcare industry wage threshold ban on noncompetes distinct from its general wage threshold ban.  In general, Maryland provides that noncompetes may not be enforced against low-wage workers earning less than 150% of the state minimum wage ($49,920 in 2026) (Md. Code, Lab. & Empl. § 3-716, effective October 1, 2023).  Healthcare providers, defined as those that provide direct patient care and are required to be licensed under the Maryland Health Occupations Article, who earn equal to or less than $350,000 annually, may similarly not be subject to noncompetes.  In Maryland, healthcare providers who earn more than $350,000 annually may be subjected to noncompetes if they do not exceed one year from the last day of employment and do not exceed a geographical restriction of 10 miles from the primary place of employment.  See Md. Code, Lab. & Empl. § 3-716, effective June 1, 2024, but affecting agreements executed on or after July 1, 2025.

Update since last post: since July 2025, the Maryland legislature is considering one new bill: H.B. 1016 (introduced January 2026), which would void noncompetes where employers relocate, reorganize, or otherwise cease to have the majority of its employees located in the state.

Industry Bans

While the most common type of industry-specific noncompete bans target the healthcare industry, seven states have implemented (in addition to healthcare-specific bans, or in lieu of them) noncompete bans or restrictions affecting non-healthcare industries, namely veterinarians or broadcasters (DC, HI, LA, ME, MD, MA, UT).

State Spotlight: District of Columbia

The District of Columbia recently instituted a blanket ban for broadcast employees, regardless of their annual compensation (D.C. Code. § 32-581.01 – 32-581.05, effective September 1, 2022).  Broadcast employees are defined as an “on- or off-air creator (such as an anchor, disc jockey, editor, producer, program host, reporter, or writer) of a legal entity that owns or operates a TV, radio, cable, or other broadcast station or network, including satellite-based services similar to a broadcast station or network.  [Other than annual increases in the wage threshold, see above, no updates since last blog post in July 2025.]

State Spotlight: Utah

Utah does not broadly ban noncompetes for broadcast employees, but instead implements a combination of restrictions for broadcast employees who make more, or less, than a defined wage threshold. (Utah Code Ann. §§ 34-51-101 – 301, effective May 10, 2016).  For broadcast employees making less than $913 per week or who qualify for overtime under the Fair Labor Standards Act, Utah permits noncompetes for up to one year; for those who make more than that wage threshold, Utah law defines the conditions the noncompete must meet in order to be enforceable, including requiring it to be “of reasonable duration” and based on industry standards.”  Broadcast employees are defined as those engaged in the business of “distributing or transmitting electronic or electromagnetic signals to the general public” using television, cable, or radio, or preparing, developing, or creating one or more programs by those means.

Update since last post: Utah has implemented a new law, Utah Code Ann. §§ 58-89-101 (effective May 7, 2025), which prohibits health care services platforms from requiring a healthcare worker to enter into a noncompete agreement.  The Utah legislature is currently considering a new bill, H.B. 203 (introduced in 2026), which would prohibit noncompetes for nonexempt employees under the FLSA, students, people less than 18 years of age, employees who earn less than $155,000, and if the employee was terminated as part of a reduction-in-force.

State Spotlight: Hawai‘i

Hawai‘i law bans noncompetes for all employees “of a technology business.”  (Haw. Rev. Stat. 480-4(d), effective January 1, 2015), which in turn is defined as a trade or business that derives the majority of its gross income from the sale or license of products or services “resulting from its software development or information technology development, or both,” and excludes businesses considered part of the broadcast industry or telecommunications carriers.  [No updates since last post in July 2025.]

State Spotlight: Maryland

Maryland law reflects a growing trend to ban noncompetes for veterinarians or vet techs: Maryland bans noncompetes restricting both types of employees.  (Md. Code, Lab. & Empl. § 3-716, effective June 1, 2024).  [See above Spotlight on Maryland for updates since last post.]

Protectable Interests

The last category of noncompete state statutes are those that do not ban, or arguably meaningfully restrict noncompetes, but instead merely define the “protectable interests” upon which an employer may justify a noncompete and/or specify the categories courts should consider when determining whether a noncompete is enforceable.  Eight states have “protectable interest” statutes outlining considerations for courts examining the enforceability of noncompete agreements (AL, FL, GA, ID, MI, MS, NC, WI).

State Spotlight: Wisconsin

Wisconsin law provides that noncompetes are only permitted if the restrictions on employment are reasonably necessary to protect the employer and do not unreasonably restrain the employee.  Wis. Stat. Ann. § 103.465, amended March 2, 2016.

Update since last post: since July 2025, the Wisconsin legislature has introduced and is now considering two new bills relating to noncompetes: WI A.B. 567 (introduced October 2025), which would void most noncompetes with few exceptions; and S.B. 657 / A.B. 675 (introduced November 2025), which would void noncompetes for medical practitioners if they restrict work for more than 24 months or if the employee was terminated.

State Spotlight: Georgia

Georgia law provides that noncompete agreements are permissible if they serve a legitimate business interest, and if they are reasonable in time, geographic area, and scope of prohibited activities, but are void if they are not supported by a “legitimate business interest.”  Ga. Code Ann. §§ 13-8-50 – 59 (May 11, 2011).  [No updates since last post in July 2025.]

Penalties

Some of the state statutes limiting or banning noncompetes do not specify penalties for violation; but many do.  A few examples are listed below:

• Colorado: penalty of $5,000 for each worker or prospective worker, injunctive relief, and actual damages; employer may also be required to pay reasonable costs and attorney fees, Rev. Stat § 8-2-113;
• District of Columbia: penalty of no less than $350 and no more than $1,000 for each violation; if agreement was entered into after non-compete ban went into effect on October 1, 2022 or if highly compensated employee’s employer failed to give notice of non-compete ban, penalty of not less than $1,000, C. Code § 32-581.04;
• Illinois: penalty not to exceed $5,000 for each violation, or $10,000 for each repeat violation within a 5-year period, 820 ILCS § 90/1;
• Maine: penalty of not less than $5,000, 26 Me. Rev. Stat. Ann. § 599-A;
• Virginia: civil penalties of $250 for second violation and $1,000 for third and each subsequent violation, plus attorneys fees, fees for expert witness(es), and costs, Code § 40.1-28.7:8; and
• Washington: penalty of $5,000, plus reasonable attorneys’ fees, expenses and costs, RCW §§ 49.62.005 – 900.

[1] See, e.g., Matthew Johnson, Kurt Lavetti, and Michael Lipsitz, The Labor Market Effects of Legal Restrictions on Worker Mobility 2 (2020), https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3455381 (finding that a nationwide ban on noncompetes would increase average earnings by 3.3–13.9%); Evan Starr, J.J. Prescott, and Norm Bishara, The Behavioral Effects of (Unenforceable) Contracts, 36 J.L., Econ., and Org. 633, 652 (2020) (finding that having a noncompete clause was associated with a 35% decrease in the likelihood a worker would leave for a competitor); Sampsa Samila and Olav Sorenson, Noncompete Covenants: Incentives to Innovate or Impediments to Growth, 57 Mgmt. Sci. 425, 432 (2011) (finding that when noncompete clauses were more enforceable, rates of entrepreneurship, patenting, and employment growth slow).