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  "data": {
    "topic": "non-compete",
    "state": "oklahoma",
    "frontmatter": {
      "title": "Non-Competes in Oklahoma",
      "description": "Oklahoma voids employee non-compete agreements by statute and allows only narrow exceptions for customer non-solicitation, employee anti-raiding, and the sale of a business.",
      "state": "Oklahoma",
      "lastReviewed": "2026-06-03",
      "license": "CC BY 4.0",
      "authors": [
        "steven-obiajulu"
      ],
      "summary": {
        "enforceability": "banned",
        "bottomLine": "Oklahoma voids employee non-competes by statute, permitting only narrow carve-outs for direct customer non-solicitation, employee anti-raiding, and sale-of-business or partnership-dissolution covenants.",
        "keyLaw": "Okla. Stat. tit. 15, § 217",
        "exceptions": "Sale of goodwill (§ 218); partnership dissolution (§ 219); direct customer non-solicit (§ 219A); employee anti-raiding (§ 219B); trade-secret clauses outside the ban",
        "courtNarrowing": "no",
        "appliesToContractors": "unclear",
        "extendedForBreach": "Not addressed",
        "maxLength": "No statutory limit on the ban; sale covenants limited to a county and contiguous counties",
        "noticeRequirement": "None",
        "incomeThreshold": "None",
        "saleOfBusiness": "Allowed — sale of goodwill (§ 218)",
        "customerNonSolicit": "Direct solicitation of established customers only (§ 219A)",
        "employeeNonSolicit": "Allowed anti-raiding clauses (§ 219B)"
      },
      "about": [
        "Oklahoma non-compete agreements",
        "Oklahoma restrictive covenants",
        "15 O.S. Section 217 restraint of trade",
        "Oklahoma customer non-solicitation statute Section 219A",
        "Oklahoma employee anti-raiding Section 219B",
        "Oklahoma sale-of-business non-compete Section 218",
        "Oklahoma non-compete choice of law and forum selection"
      ],
      "translations": [
        {
          "language": "中文",
          "status": "planned"
        },
        {
          "language": "Español",
          "status": "planned"
        },
        {
          "language": "Português",
          "status": "planned"
        },
        {
          "language": "Deutsch",
          "status": "planned"
        }
      ],
      "relatedForm": {
        "slug": "openagreements-restrictive-covenant-oklahoma"
      }
    },
    "questions": [
      {
        "slug": "employee-non-compete-enforceability",
        "label": "Are employee non-competes enforceable?",
        "heading": "Are employee non-compete agreements enforceable in Oklahoma?",
        "answerText": "No. Oklahoma voids employee non-compete agreements by statute. A contract that restrains someone from exercising a lawful profession, trade, or business is void to that extent, except for the narrowly drawn covenants Oklahoma statutes specifically permit: sale-of-goodwill covenants (§ 218), partnership-dissolution covenants (§ 219), direct solicitation of established customers (§ 219A), and employee anti-raiding clauses (§ 219B).",
        "sources": [
          {
            "id": "stat-217-general-void",
            "authorityType": "primary-law",
            "tier": "primary-source-backed",
            "title": "15 O.S. § 217",
            "citation": "Okla. Stat. tit. 15, § 217.",
            "url": "https://oksenate.gov/sites/default/files/2022-05/os15.pdf",
            "proposition": "Section 217 voids any contract that restrains a person from exercising a lawful profession, trade, or business, except as provided by §§ 218 and 219 and the related customer non-solicitation rule (§ 219A); § 219B separately removes qualifying anti-raiding clauses from the prohibition.",
            "verbatimQuote": "Every contract by which any one is restrained from exercising a lawful profession, trade or business of any kind, otherwise than as provided by Sections 218 and 219 of this title, or otherwise than as provided by Section 2 of this act, is to that extent void.",
            "anchor": "https://openagreements.org/practice-guides/non-compete/us/oklahoma#src-stat-217-general-void"
          },
          {
            "id": "stat-219a-void-clause",
            "authorityType": "primary-law",
            "tier": "primary-source-backed",
            "title": "15 O.S. § 219A",
            "citation": "Okla. Stat. tit. 15, § 219A(B).",
            "url": "https://oksenate.gov/sites/default/files/2022-05/os15.pdf",
            "proposition": "Section 219A(B) makes any employment-contract provision that conflicts with the statute void and unenforceable.",
            "verbatimQuote": "Any provision in a contract between an employer and an employee in conflict with the provisions of this section shall be void and unenforceable.",
            "anchor": "https://openagreements.org/practice-guides/non-compete/us/oklahoma#src-stat-219a-void-clause"
          },
          {
            "id": "howard-noncompete-void",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Howard v. Nitro-Lift Technologies, L.L.C.",
            "citation": "Howard v. Nitro-Lift Techs., L.L.C., 2011 OK 98, 273 P.3d 20, vacated on other grounds sub nom. Nitro-Lift Techs., L.L.C. v. Howard, 568 U.S. 17 (2012).",
            "url": "https://www.courtlistener.com/opinion/5327051/howard-v-nitro-lift-technologies-llc/",
            "deepLink": "https://www.courtlistener.com/opinion/5327051/howard-v-nitro-lift-technologies-llc/#:~:text=The%20non%2Dcompetition%20contracts%20go%20well,the%20legislatively%20expressed%20public%20policy.",
            "proposition": "Howard reflects Oklahoma's rule that conventional non-competition covenants are void because they exceed what § 219A allows and violate the state's legislatively expressed public policy; the decision was vacated on arbitration-procedure grounds, but the statutory rule it applied remains good law.",
            "verbatimQuote": "The non-competition contracts go well beyond the bounds of what is allowable under § 219A and violate the legislatively expressed public policy.",
            "date": "2011-11-22",
            "anchor": "https://openagreements.org/practice-guides/non-compete/us/oklahoma#src-howard-noncompete-void"
          }
        ]
      },
      {
        "slug": "customer-nonsolicitation",
        "label": "Can you restrict customer solicitation?",
        "heading": "What customer non-solicitation restrictions does Oklahoma allow?",
        "answerText": "Only a narrow one. Under 15 O.S. § 219A a former employee may compete, but the agreement may bar the employee from directly soliciting the established customers of the former employer. A clause that reaches further — indirect solicitation, or prospective and former customers — is void.",
        "sources": [
          {
            "id": "stat-219a-rule",
            "authorityType": "primary-law",
            "tier": "primary-source-backed",
            "title": "15 O.S. § 219A",
            "citation": "Okla. Stat. tit. 15, § 219A(A).",
            "url": "https://oksenate.gov/sites/default/files/2022-05/os15.pdf",
            "proposition": "Section 219A(A) lets a former employee compete so long as the agreement bars only direct solicitation of the former employer's established customers.",
            "verbatimQuote": "A person who makes an agreement with an employer, whether in writing or verbally, not to compete with the employer after the employment relationship has been terminated, shall be permitted to engage in the same business as that conducted by the former employer or in a similar business as that conducted by the former employer as long as the former employee does not directly solicit the sale of goods, services or a combination of goods and services from the established customers of the former employer.",
            "anchor": "https://openagreements.org/practice-guides/non-compete/us/oklahoma#src-stat-219a-rule"
          },
          {
            "id": "autry-no-sever",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Autry v. Acosta, Inc.",
            "citation": "Autry v. Acosta, Inc., 2018 OK CIV APP 8, 410 P.3d 1017.",
            "url": "https://www.courtlistener.com/opinion/4520541/autry-v-acosta-inc/",
            "deepLink": "https://www.courtlistener.com/opinion/4520541/autry-v-acosta-inc/#:~:text=We%20find%20that%20the%20remedy,merely%20deleting%20the%20word%20%E2%80%9Cindirectly.%E2%80%9D",
            "proposition": "Autry holds that a non-solicitation agreement reaching indirect solicitation cannot be cured by simply deleting the word indirectly — the court will not blue-pencil it.",
            "verbatimQuote": "We find that the remedy for this Non-Solicitation Agreement's shortcomings is not quite that simple and it cannot be made to comply with § 219A by merely deleting the word “indirectly.”",
            "date": "2017-11-14",
            "anchor": "https://openagreements.org/practice-guides/non-compete/us/oklahoma#src-autry-no-sever"
          },
          {
            "id": "autry-void",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Autry v. Acosta, Inc.",
            "citation": "Autry v. Acosta, Inc., 2018 OK CIV APP 8, 410 P.3d 1017.",
            "url": "https://www.courtlistener.com/opinion/4520541/autry-v-acosta-inc/",
            "deepLink": "https://www.courtlistener.com/opinion/4520541/autry-v-acosta-inc/#:~:text=Examined%20under%20the%20lens%20of,Legislature's%20enactment%20of%20that%20section.",
            "proposition": "Autry holds that the overbroad non-solicitation agreement was void and unenforceable as against Oklahoma public policy under § 219A.",
            "verbatimQuote": "Examined under the lens of § 219A, the Non-Solicitation Agreement is void and unenforceable as against Oklahoma's public policy expressed by the Legislature's enactment of that section.",
            "date": "2017-11-14",
            "anchor": "https://openagreements.org/practice-guides/non-compete/us/oklahoma#src-autry-void"
          },
          {
            "id": "inergy-rule-of-reason",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Inergy Propane, LLC v. Lundy",
            "citation": "Inergy Propane, LLC v. Lundy, 2009 OK CIV APP 8, 219 P.3d 547.",
            "url": "https://www.courtlistener.com/opinion/2629577/inergy-propane-llc-v-lundy/",
            "deepLink": "https://www.courtlistener.com/opinion/2629577/inergy-propane-llc-v-lundy/#:~:text=That%20does%20not%2C%20however%2C%20require,by%20previously%20established%20case%20law.",
            "proposition": "Inergy holds that § 219A did not abolish the common-law rule of reason; a customer non-solicitation covenant must still be reasonable in scope and duration.",
            "verbatimQuote": "That does not, however, require abandonment of the rule of reason analysis required by previously established case law.",
            "date": "2008-08-13",
            "anchor": "https://openagreements.org/practice-guides/non-compete/us/oklahoma#src-inergy-rule-of-reason"
          }
        ]
      },
      {
        "slug": "employee-nonsolicitation",
        "label": "Can you restrict soliciting employees?",
        "heading": "Can an Oklahoma employer restrict soliciting its employees?",
        "answerText": "Yes. 15 O.S. § 219B expressly allows an employee anti-raiding covenant that bars a former employee from soliciting the employer's employees or independent contractors — and, unlike the customer rule, it may reach direct or indirect solicitation.",
        "sources": [
          {
            "id": "stat-219b-antiraid",
            "authorityType": "primary-law",
            "tier": "primary-source-backed",
            "title": "15 O.S. § 219B",
            "citation": "Okla. Stat. tit. 15, § 219B.",
            "url": "https://oksenate.gov/sites/default/files/2022-05/os15.pdf",
            "proposition": "Section 219B permits an anti-raiding covenant barring direct or indirect solicitation of a business's employees or independent contractors, and exempts it from the restraint-of-trade prohibition.",
            "verbatimQuote": "A contract or contractual provision which prohibits an employee or independent contractor of a person or business from soliciting, directly or indirectly, actively or inactively, the employees or independent contractors of that person or business to become employees or independent contractors of another person or business shall not be construed as a restraint from exercising a lawful profession, trade or business of any kind.",
            "anchor": "https://openagreements.org/practice-guides/non-compete/us/oklahoma#src-stat-219b-antiraid"
          }
        ]
      },
      {
        "slug": "sale-of-business",
        "label": "Are sale-of-business non-competes allowed?",
        "heading": "Are non-competes tied to the sale of a business enforceable in Oklahoma?",
        "answerText": "Yes, within statutory limits. Under 15 O.S. § 218 the seller of a business's goodwill may agree not to compete within a specified county and contiguous counties, or a specified city or town. A parallel rule in § 219 allows the same on the dissolution of a partnership.",
        "sources": [
          {
            "id": "stat-218-goodwill",
            "authorityType": "primary-law",
            "tier": "primary-source-backed",
            "title": "15 O.S. § 218",
            "citation": "Okla. Stat. tit. 15, § 218.",
            "url": "https://oksenate.gov/sites/default/files/2022-05/os15.pdf",
            "proposition": "Section 218 lets the seller of a business's goodwill agree not to compete within a specified county and contiguous counties, or a specified city or town, and expressly allows a court to reform overbroad geography to the primary county and contiguous counties.",
            "verbatimQuote": "One who sells the goodwill of a business may agree with the buyer to refrain from carrying on a similar business within a specified county and any county or counties contiguous thereto, or a specified city or town or any part thereof, so long as the buyer, or any person deriving title to the goodwill from him carries on a like business therein. Provided, that any such agreement which is otherwise lawful but which exceeds the territorial limitations specified by this section may be deemed valid, but only within the county comprising the primary place of the conduct of the subject business and within any counties contiguous thereto.",
            "anchor": "https://openagreements.org/practice-guides/non-compete/us/oklahoma#src-stat-218-goodwill"
          },
          {
            "id": "stat-219-partners",
            "authorityType": "primary-law",
            "tier": "primary-source-backed",
            "title": "15 O.S. § 219",
            "citation": "Okla. Stat. tit. 15, § 219.",
            "url": "https://oksenate.gov/sites/default/files/2022-05/os15.pdf",
            "proposition": "Section 219 lets partners, on or in anticipation of dissolution, agree not to carry on a similar business within a specified county and contiguous counties, or a specified city or town, and carries the same statutory territorial reformation rule as § 218.",
            "verbatimQuote": "Partners may, upon or in anticipation of a dissolution of the partnership, agree that none of them will carry on a similar business within a specified county and any county or counties contiguous thereto, or a specified city or town or any part thereof. Provided, that any such agreement which is otherwise lawful but which exceeds the territorial limitations specified by this section may be deemed valid, but only within the county comprising the primary place of the conduct of the business of the subject partnership and within any counties contiguous thereto.",
            "anchor": "https://openagreements.org/practice-guides/non-compete/us/oklahoma#src-stat-219-partners"
          },
          {
            "id": "berry-218-goodwill",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Berry & Berry Acquisitions, LLC v. BFN Props. LLC",
            "citation": "Berry & Berry Acquisitions, LLC v. BFN Props. LLC, 2018 OK 27, 416 P.3d 1061.",
            "url": "https://www.courtlistener.com/opinion/4483518/berry-berry-acquisitions-llc-v-bfn-props-llc/",
            "deepLink": "https://www.courtlistener.com/opinion/4483518/berry-berry-acquisitions-llc-v-bfn-props-llc/#:~:text=We%20have%20consistently%20upheld%20non%2Dcompete,goodwill%20pursuant%20to%20%C2%A7%20218.",
            "proposition": "Berry confirms that Oklahoma courts consistently uphold non-compete agreements that protect business goodwill under § 218.",
            "verbatimQuote": "We have consistently upheld non-compete agreements to protect business goodwill pursuant to § 218.",
            "date": "2018-04-03",
            "anchor": "https://openagreements.org/practice-guides/non-compete/us/oklahoma#src-berry-218-goodwill"
          },
          {
            "id": "eakle-218-reform",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Eakle v. Grinnell Corp.",
            "citation": "Eakle v. Grinnell Corp., 272 F. Supp. 2d 1304 (E.D. Okla. 2003).",
            "url": "https://www.courtlistener.com/opinion/2296282/eakle-v-grinnell-corp/",
            "deepLink": "https://www.courtlistener.com/opinion/2296282/eakle-v-grinnell-corp/#:~:text=The%20Oklahoma%20Supreme%20Court%20has,restrictions%20found%20in%20section%20218.",
            "proposition": "Eakle states that valid sale-of-goodwill non-competes are subject to modification of their territorial restrictions under § 218.",
            "verbatimQuote": "The Oklahoma Supreme Court has held that non-compete agreements in connection with the sale of goodwill, which are otherwise valid, are subject to modification with respect to the territorial restrictions found in section 218.",
            "date": "2003-06-11",
            "anchor": "https://openagreements.org/practice-guides/non-compete/us/oklahoma#src-eakle-218-reform"
          },
          {
            "id": "bayly-appreciable-interest",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Bayly, Martin & Fay, Inc. v. Pickard",
            "citation": "Bayly, Martin & Fay, Inc. v. Pickard, 1989 OK 122, 780 P.2d 1168.",
            "url": "https://www.courtlistener.com/opinion/1190912/bayly-martin-fay-inc-v-pickard/",
            "deepLink": "https://www.courtlistener.com/opinion/1190912/bayly-martin-fay-inc-v-pickard/#:~:text=Court%20held%20that%20the%20sale,the%20meaning%20of%20%C2%A7%20218.",
            "proposition": "Bayly indicates that only the sale of an appreciable ownership interest can qualify as a sale of goodwill within the meaning of § 218.",
            "verbatimQuote": "Court held that the sale of an appreciable amount of stock, there 20%, could constitute a sale of good will within the meaning of § 218.",
            "date": "1989-09-26",
            "anchor": "https://openagreements.org/practice-guides/non-compete/us/oklahoma#src-bayly-appreciable-interest"
          }
        ]
      },
      {
        "slug": "consideration",
        "label": "Is continued employment enough consideration?",
        "heading": "Does continued employment count as consideration for an Oklahoma restrictive covenant?",
        "answerText": "It is unsettled. Oklahoma has not squarely decided whether continued at-will employment, by itself, is sufficient consideration for a restrictive covenant signed mid-employment. Whatever the consideration, the covenant must still fit § 219A or § 219B, or it is void regardless.",
        "sources": [
          {
            "id": "stat-219a-void-consideration",
            "authorityType": "primary-law",
            "tier": "primary-source-backed",
            "title": "15 O.S. § 219A",
            "citation": "Okla. Stat. tit. 15, § 219A(B).",
            "url": "https://oksenate.gov/sites/default/files/2022-05/os15.pdf",
            "proposition": "Section 219A(B) voids any employment-contract provision in conflict with the statute, so consideration cannot save a covenant that exceeds what § 219A permits.",
            "verbatimQuote": "Any provision in a contract between an employer and an employee in conflict with the provisions of this section shall be void and unenforceable.",
            "anchor": "https://openagreements.org/practice-guides/non-compete/us/oklahoma#src-stat-219a-void-consideration"
          }
        ]
      },
      {
        "slug": "trade-secrets",
        "label": "Are confidentiality and trade-secret clauses enforceable?",
        "heading": "Are confidentiality and trade-secret protections still enforceable in Oklahoma?",
        "answerText": "Yes. A confidentiality or trade-secret clause does not restrain a person from working — it restrains the misuse of protected information — so it sits outside the § 217 ban. The Oklahoma Uniform Trade Secrets Act backs that protection with injunctive relief and damages.",
        "sources": [
          {
            "id": "outsa-injunction",
            "authorityType": "primary-law",
            "tier": "primary-source-backed",
            "title": "78 O.S. § 87",
            "citation": "Okla. Stat. tit. 78, § 87(A).",
            "url": "https://oksenate.gov/sites/default/files/2022-05/os78.pdf",
            "proposition": "Section 87 of the Oklahoma Uniform Trade Secrets Act authorizes injunctive relief against actual or threatened misappropriation of a trade secret.",
            "verbatimQuote": "Actual or threatened misappropriation may be enjoined.",
            "anchor": "https://openagreements.org/practice-guides/non-compete/us/oklahoma#src-outsa-injunction"
          }
        ]
      },
      {
        "slug": "choice-of-law",
        "label": "Can another state's law be used to escape the ban?",
        "heading": "Can a choice-of-law or forum-selection clause escape Oklahoma's non-compete ban?",
        "answerText": "Sometimes. An Oklahoma court will not apply a contractually chosen foreign law if doing so would violate Oklahoma public policy — so a Delaware or Texas choice-of-law clause will not, by itself, resurrect a void employee non-compete. But a mandatory forum-selection clause is a different lever: a federal court in Oklahoma has enforced one to transfer the dispute out of Oklahoma, after which the employer obtained injunctive relief under the chosen state's law.",
        "sources": [
          {
            "id": "eakle-public-policy",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Eakle v. Grinnell Corp.",
            "citation": "Eakle v. Grinnell Corp., 272 F. Supp. 2d 1304 (E.D. Okla. 2003).",
            "url": "https://www.courtlistener.com/opinion/2296282/eakle-v-grinnell-corp/",
            "deepLink": "https://www.courtlistener.com/opinion/2296282/eakle-v-grinnell-corp/#:~:text=As%20this%20general%20rule%20recognizes%2C,policy%20of%20the%20forum%20state.",
            "proposition": "Eakle states that an Oklahoma forum court will not apply a contractually chosen foreign law where doing so would violate Oklahoma public policy.",
            "verbatimQuote": "As this general rule recognizes, however, the forum court will not apply the law chosen by the contracting parties should doing so violate the public policy of the forum state.",
            "date": "2003-06-11",
            "anchor": "https://openagreements.org/practice-guides/non-compete/us/oklahoma#src-eakle-public-policy"
          },
          {
            "id": "griffin-order",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Griffin v. Howmedica Osteonics Corp.",
            "citation": "Griffin v. Howmedica Osteonics Corp., No. 25-CV-302-JFJ (N.D. Okla. Oct. 2, 2025).",
            "url": "https://www.courtlistener.com/docket/70562720/21/griffin-v-howmedica-osteonics-corporation/",
            "deepLink": "https://www.courtlistener.com/docket/70562720/21/griffin-v-howmedica-osteonics-corporation/#:~:text=Plaintiff%20has%20therefore%20not%20met,to%20the%20contractually%20selected%20forum.",
            "proposition": "In Griffin, the Northern District of Oklahoma enforced a mandatory Michigan forum-selection clause and transferred an Oklahoma employee's declaratory-judgment action out of Oklahoma, holding that Oklahoma's public policy against non-competes was not an exceptional circumstance defeating transfer — even though the court acknowledged it would likely find the covenants void under Oklahoma law if the case stayed.",
            "verbatimQuote": "Plaintiff has therefore not met his burden of showing that exceptional circumstances exist that counsel against transfer to the contractually selected forum.",
            "date": "2025-10-02",
            "anchor": "https://openagreements.org/practice-guides/non-compete/us/oklahoma#src-griffin-order"
          },
          {
            "id": "griffin-forum-selection",
            "authorityType": "law-firm-commentary",
            "tier": "lawyer-judgment-backed",
            "title": "GableGotwals — Restrictive Covenants for Oklahoma Employees: Lessons from Griffin v. Stryker",
            "citation": "GableGotwals, Restrictive Covenants for Oklahoma Employees: Lessons from Griffin v. Stryker (Feb. 26, 2026).",
            "url": "https://www.gablelaw.com/restrictive-covenants-for-oklahoma-employees-lessons-from-griffin-v-stryker/",
            "proposition": "GableGotwals reports that the Northern District of Oklahoma enforced a mandatory Michigan forum-selection clause in Griffin v. Stryker, holding Oklahoma's anti-non-compete policy was not an exceptional circumstance defeating transfer, after which the Michigan court issued a preliminary injunction against the Oklahoma employee.",
            "verbatimQuote": "The court acknowledged Oklahoma’s strong policy against non-competes and said if the case stayed in Oklahoma, it would “likely” find the non‑competition/non‑solicitation provisions void. Nevertheless, it concluded that Oklahoma’s policy interest did not constitute the type of “exceptional circumstance” needed to override the parties’ mandatory Michigan forum selection, and it also referenced judicial interests against forum shopping and a race to the courthouse.",
            "date": "2026-02-26",
            "anchor": "https://openagreements.org/practice-guides/non-compete/us/oklahoma#src-griffin-forum-selection"
          }
        ]
      },
      {
        "slug": "recent-developments",
        "label": "What recent changes should employers watch?",
        "heading": "What recent legislative developments affect Oklahoma non-competes?",
        "answerText": "The framework held steady through the last attempt to loosen it. In 2024 the Legislature passed Senate Bill 1543, which would have broadened § 219A to let employers bar customer solicitation directly or indirectly and to reach independent contractors — but Governor Stitt vetoed it, and the veto was not overridden.",
        "sources": [
          {
            "id": "autry-indirect-recent",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Autry v. Acosta, Inc.",
            "citation": "Autry v. Acosta, Inc., 2018 OK CIV APP 8, 410 P.3d 1017.",
            "url": "https://www.courtlistener.com/opinion/4520541/autry-v-acosta-inc/",
            "deepLink": "https://www.courtlistener.com/opinion/4520541/autry-v-acosta-inc/#:~:text=We%20find%20that%20the%20remedy,merely%20deleting%20the%20word%20%E2%80%9Cindirectly.%E2%80%9D",
            "proposition": "Autry holds that a non-solicitation agreement reaching indirect solicitation cannot be cured by deleting the word indirectly — the controlling construction of § 219A that SB 1543's veto left undisturbed.",
            "verbatimQuote": "We find that the remedy for this Non-Solicitation Agreement's shortcomings is not quite that simple and it cannot be made to comply with § 219A by merely deleting the word “indirectly.”",
            "anchor": "https://openagreements.org/practice-guides/non-compete/us/oklahoma#src-autry-indirect-recent"
          },
          {
            "id": "sb1543-enrolled",
            "authorityType": "primary-law",
            "tier": "primary-source-backed",
            "title": "Enrolled Senate Bill 1543 (2024)",
            "citation": "Enrolled S.B. 1543, 59th Leg., 2d Reg. Sess. (Okla. 2024) (vetoed).",
            "url": "https://www.oklegislature.gov/cf_pdf/2023-24%20ENR/SB/SB1543%20ENR.PDF",
            "proposition": "Enrolled SB 1543 would have amended 15 O.S. § 219A to let a covenant bar customer solicitation directly or indirectly, actively or inactively, and to reach independent contractors; it was passed but vetoed and never took effect.",
            "verbatimQuote": "A person who makes an agreement with an employer, whether in writing or verbally, not to compete with the employer after the employment relationship has been terminated, shall be permitted to engage in the same business as that conducted by the former employer or in a similar business as that conducted by the former employer as long as the former employee does not directly solicit, directly or indirectly, actively or inactively, the sale of goods, services or a combination of goods and services from the established customers or independent contractors of the former employer.",
            "date": "2024-04-25",
            "anchor": "https://openagreements.org/practice-guides/non-compete/us/oklahoma#src-sb1543-enrolled"
          },
          {
            "id": "mcafeetaft-sb1543-veto",
            "authorityType": "law-firm-commentary",
            "tier": "lawyer-judgment-backed",
            "title": "McAfee & Taft — Oklahoma Legislature Passes Bill Broadening Scope of Permissible Non-Solicitation Agreements",
            "citation": "McAfee & Taft, Oklahoma Legislature Passes Bill Broadening Scope of Permissible Non-Solicitation Agreements (Apr. 2024).",
            "url": "https://www.mcafeetaft.com/oklahoma-legislature-passes-bill-broadening-scope-of-permissible-non-solicitation-agreements/",
            "proposition": "McAfee & Taft reports that Senate Bill 1543, which would have broadened permissible non-solicitation agreements, was vetoed by Governor Stitt on April 30, 2024 and not overridden.",
            "verbatimQuote": "UPDATE: Oklahoma Governor Kevin Stitt vetoed this bill April 30, 2024, and the Legislature did not override the veto in the 2024 legislative session.",
            "date": "2024-04-25",
            "anchor": "https://openagreements.org/practice-guides/non-compete/us/oklahoma#src-mcafeetaft-sb1543-veto"
          }
        ]
      }
    ]
  }
}
