In DCS Sanitation Management v.Castillo,where employees signed an agreement not to work for a competitor within 100 miles,the appeals court held that all non-competition agreements could not be enforced.

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The appeals court held that the specific non-competition agreement in question, which barred employees from working for a competitor within 100 miles, was overly broad and therefore unenforceable. The court did not make a blanket statement that all non-competition agreements are unenforceable.

In DCS Sanitation Management V