Metroplex Pathology Assocs. v. Horn (Summary)

BREACH OF CONTRACT

Metroplex Pathology Assocs. v. Horn, Civil Action No. 12-11024-RWZ (D. Mass. Jan. 2, 2013)

The United States District Court for the District of Massachusetts denied a pathology lab’s motion for preliminary injunction to prevent former employees from violating restrictions in their employment agreements.  The court also denied a defending physician’s motion to seal certain documents regarding the sale of a clinical laboratory that he had partially owned.  A team of physicians created a corporation that provided specialized pathology services.  The physicians sold their corporation and, upon selling the corporation, they entered into restrictive employment contracts with the buyer.  After the physicians became dissatisfied with the management of their business, they each left and joined the same specialized pathology lab that was operated by a local hospital.

The owner of the physicians’ former corporation sued for breach of contract and sought a preliminary injunction to restrain the physicians from violating the restrictions in their employment contracts.  However, the court denied the motion for preliminary injunction because it concluded that the owner failed to provide evidence that the physicians had violated any of the restrictive provisions in their employment contract.  Specifically, the court noted that the owner had failed to identify any instances when the physicians had disclosed or used any confidential information from the owner’s business.  Furthermore, the court concluded that the owner had failed to provide evidence that the physicians had disparaged the owner.  Finally, the court concluded that the owner had failed to prove that the local hospital that now employs the physicians had intentionally interfered in any way with the owner’s contractual relationships with the physicians.  Accordingly, the court denied the owner’s motion for a preliminary injunction.

With regard to the physician’s motion to seal documents relevant to the sale of the clinical laboratory, the court concluded that the physician failed to provide “good cause” for sealing the documents.  Thus, the court denied the motion to seal.