Life Time Fitness, Inc. v. DeCelles, 854 F. Supp. 2d 690

LTF is a Minnesota corporation with nationwide clubs, including five in Arizona, offering personal training services.
DeCelles was employed as a personal trainer at LTF Tempe, responsible for member recruitment, program design, and maintaining health and contact data.
DeCelles signed a noncompete and CBPI protection agreement restricting use of confidential information and restricting competition after employment.
DeCelles left LTF in Nov 2011 and allegedly took 30-40 LTF client files to his new employer, Arizona Spine and Disc, then joined Pro Fitness in Jan 2012.
PF allegedly contacted LTF members and solicited business; some LTF members canceled memberships or sought refunds after DeCelles’ departure; LTF alleges missing original member contracts.
LTF moved for a TRO, the court held a hearing, and issues this order granting TRO in part.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does Minnesota forum selection clause render jurisdiction proper?	LTF argues clause consents to Minnesota courts for venue/jurisdiction.	DeCelles contests, but does not challenge forum clause as improper.	Jurisdiction proper; forum clause valid and enforceable.
Should a TRO be issued under Dataphase factors given Minnesota law?	LTF shows irreparable harm, balance of harms favorable, likelihood of success on a claim, and public interest favoring enforcement.	DeCelles contends the balance harms and likelihood factors do not warrant relief.	TRO warranted after balancing four factors.
Is the noncompete reasonable and likely to be enforced against DeCelles?	Restricts time, geographic scope, and is necessary to protect goodwill and confidential information.	Noncompete overly broad or unnecessary.	Covenant deemed reasonable; likely to succeed on breach of contract.
Does public interest support issuing a TRO in this context?	Public interest supports enforcing contractual restraints and protecting confidential information.	Public interest in competition and restraint restrictions must be weighed.	Public interest favors LTF; TRO appropriate.

Dominium Austin Partners, L.L.C. v. Emerson, 248 F.3d 720 (8th Cir. 2001) (consent-based personal jurisdiction via forum selection clause)
M.B. Rests., Inc. v. CKE Rests., Inc., 183 F.3d 750 (8th Cir. 1999) (forum selection clauses are prima facie valid)
Bel Canto Design, Ltd. v. MSS HiFi, 813 F. Supp. 2d 1119 (D. Minn. 2011) (transferring venue after TRO, discussion of venue propriety)
Mo. Housing Dev. Comm’n v. Brice, 919 F.2d 1306 (8th Cir. 1990) (permits consideration of multiple proper venues)
Rosewood Mortg. Corp. v. Hefty, 383 N.W.2d 456 (Minn. Ct. App. 1986) (irreparable harm from professional employee's influence on clients)
S & M Constructors, Inc. v. Foley Co., 959 F.2d 97 (8th Cir. 1992) (DATAPHASE factors guidance for TROs)
Medtronic, Inc. v. Advanced Bionics Corp., 630 N.W.2d 438 (Minn. Ct. App. 2001) (reasonableness of noncompete considering interests)
Overholt Crop Ins. Serv. Co. v. Bredeson, 437 N.W.2d 698 (Minn. Ct. App. 1989) (geographic restrictions reasonable to protect employer)
Boston Scientific Corp. v. Du-berg, 754 F. Supp. 2d 1033 (D. Minn. 2010) (one-year restrictions often deemed reasonable)