Michigan Noncompete Agreements: A 2026 Decision Shows the Risk of Drafting Too Broadly

What happened in A-Line Staffing Solutions v. Miller?

A-Line Staffing Solutions employed Verline Miller as a Recruiting Technology Analyst. His work involved IT support, technology training, data management, and software used by the company’s recruiters. He did not work directly with clients or candidates and was not involved in setting business strategy.

Miller left A-Line in late 2025 and went to work for another staffing company. A-Line sued and asked the court for a preliminary injunction enforcing his noncompete.

The agreement barred Miller for 18 months from working, directly or indirectly, with a competing business or a company offering similar products or services. The restriction was not limited to work similar to what Miller had done for A-Line.

On February 17, 2026, the Macomb County Business Court declined to issue the injunction. The court concluded that A-Line had not shown a sufficient likelihood of succeeding on its noncompete claim. Read the court’s opinion in A-Line Staffing Solutions, LLC v. Miller (PDF).

Are noncompete agreements enforceable in Michigan?

Yes. Michigan law permits an employer to obtain a noncompete agreement that protects a reasonable competitive business interest.

Under MCL 445.774a, the restriction must be reasonable as to:

• duration;
• geographic area; and
• the type of employment or line of business covered.

Michigan courts may narrow an unreasonable restriction and enforce it as modified. But an employer should not count on a court to rescue an agreement that was drafted too broadly in the first place.

What was wrong with A-Line’s restriction?

The central problem was fit.

A-Line had legitimate concerns about confidential information. Miller had access to technology systems and certain internal information, including a pricing and margin system. The court accepted that at least some of that information was confidential.

But Miller’s new job was back-end technology work. He was not going to solicit A-Line customers, recruit A-Line candidates, or use the company’s pricing information in his new position.

That made it harder for A-Line to explain why Miller needed to be barred from working for the competitor altogether.

The noncompete also applied regardless of what job Miller performed for a competing company. In practical terms, it tried to prohibit the employer rather than the competitive activity.

That is an important distinction.

What should a Michigan noncompete actually protect?

A noncompete should be tied to a real competitive risk.

Depending on the employee, that may include:

• customer relationships;
• confidential pricing;
• trade secrets;
• proprietary processes;
• strategic information; or
• other knowledge that could give a competitor an unfair advantage.

The same restriction will not make sense for every employee.

A salesperson who manages major customer accounts presents a different risk from an IT employee with no customer contact. A senior executive with access to pricing and strategic plans presents a different risk from an administrative employee.

The agreement should reflect those differences. A careful contract drafting and review process can identify those differences before a dispute arises.

Is confidential information enough by itself?

Not necessarily.

An employer must be able to identify what is actually confidential and why the employee’s use of it in a new position would create a competitive problem.

That issue received considerable attention in A-Line.

The company argued that Miller had access to confidential information about its technology, software configurations, pricing tools, and artificial-intelligence prompts. The court did not simply accept those labels.

Some information was protected. Other information was not shown to be genuinely proprietary. For example, the court was not persuaded that the company’s use of common third-party technology was confidential merely because Miller knew which products it used.

The broader point is familiar but worth repeating: putting the word “confidential” in an agreement does not make information confidential.

A business that wants to protect sensitive information should also treat it that way. Access should be limited. Sensitive materials should be identified. Employees should know what information is restricted and why.

Should every employee sign the same noncompete?

Probably not.

Form agreements are convenient, but convenience can produce restrictions that bear little relationship to the employee’s actual job.

Before requiring a noncompete, an employer should ask:

• What exactly are we trying to protect?
• What does this employee know or control?
• What competing work would create a real problem?
• Would a customer nonsolicitation provision be enough?
• Would a confidentiality agreement address the risk without restricting future employment?

Those questions often lead to a narrower agreement. That is not necessarily a weakness. A restriction that is easier to justify may be more useful when the employer actually needs to enforce it.

What does A-Line mean for Michigan employers?

A-Line does not hold that Michigan noncompetes are generally unenforceable. It is a trial-court decision involving a request for preliminary injunctive relief, and its facts matter.

But the case illustrates a practical drafting problem.

An employer may have good reasons to protect confidential information and customer relationships. That does not automatically justify preventing a former employee from taking any job with a competitor.

The better approach is to identify the particular risk and write the restriction around it.

For Michigan businesses, that work is best done when the agreement is signed, not after the employee has left and litigation has started.