In Servro Industries,Inc.v.Pizzillo,Pizzillo was a franchisee who signed an agreement with the franchisor Servpro,not to work for a competing company within 25 miles of his territory for a period of two years after the franchise terminates.Within the two year period after the termination of the franchise Pizzillo's wife opened a similar company which Pizzillo started to work for.Servpro sued to stop him from competing and the court said:

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The court held that the noncompetition clause could be enforced because Pizzillo was breaching fiduciary duties imposed by the contract even after termination by soliciting customers and acting to harm Servpro's business. The clause did not deprive Pizzillo's right to work as he could have worked for a company outside the 25-mile radius.