EMC Corp. v. Arturi
655 F.3d 75
1st Cir.2011Background
- EMC sued former employee Blotto in diversity, seeking a preliminary injunction to enforce noncompetition, non-solicitation, and protect confidential information.
- Blotto signed the employment agreement in 2007 and left EMC on December 4, 2009.
- EMC moved for a preliminary injunction on November 8, 2010; hearing held December 1, 2010.
- District Court denied the injunction on December 15, 2010, ruling the one-year restraint had expired, restricting equitable relief.
- First Circuit affirmed the denial on the narrow issue of law, applying Massachusetts state equity standards as governing in diversity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the one-year restraint expired barred equitable relief. | EMC argues equitable relief remains available despite expiration. | Blotto argues the restraint expired, foreclosing specific relief. | Yes; expiration bars specific relief. |
| Whether Massachusetts law limits injunctions after the restraint expires in diversity cases. | EMC asserts broader equitable enforcement should apply. | Blotto contends the authorities permit extended relief in some circumstances. | Massachusetts rule limits relief after expiration; only damages possible. |
| Whether the district court should toll or adjust the restraint period during litigation. | EMC could have sought tolling or a commencement upon breach. | Blotto contends no tolling was appropriate under governing law. | EMC had opportunities but did not pursue tolling; no tolling granted. |
| Whether federal courts in diversity must follow All Stainless and A-Copy as controlling authority. | EMC relies on these authorities to extend relief. | Blotto argues these cases should allow exemptions. | Massachusetts authorities control; All Stainless/A-Copy limit relief after expiration. |
| Whether claims against other defendants or issues affected the ruling on equitable relief. | EMC references broader facts to support relief. | Only the one-year period and state-law standard matter here. | Ruling limited to the narrow issue; other facts not controlling for this decision. |
Key Cases Cited
- A-Copy, Inc. v. Michaelson, 599 F.2d 450 (1st Cir. 1978) (reversed order enjoining competition after expiration; supports expiration-after-rule)
- All Stainless, Inc. v. Colby, 364 Mass. 773, 308 N.E.2d 481 (Mass. 1974) (when restraint expires, injunction may be inappropriate; damages remedy available)
- Sentry Ins. v. Firnstein, 442 N.E.2d 46 (Mass. App. Ct. 1982) (policy against unequal bargaining power; construe against employer)
- Phuong Luc v. Wyndham Mgmt. Corp., 496 F.3d 85 (1st Cir. 2007) (diversity court must apply state-law on equity once state has spoken)
- All Stainless (Mass. case cited for context; see above), 308 N.E.2d 481 (Mass. 1974) (see All Stainless detailed rule on expiration and damages)