This Law Firm Publication by Ogletree, Deakins, Nash, Smoak & Stewart, P.C. discusses the Illinois Supreme Court's recent refusal to review the controversial decision of the Appellate Court of Illinois in Fifield v. Premier Dealer Services, Inc. On June 24, 2013, in Fifield, the appellate court held that if an employee signs a restrictive covenant on hiring and is given no additional consideration other than the job itself, the employee must be employed for two years for adequate consideration to be found to enforce the restrictive covenant. In light of the Illinois Supreme Court's refusal to review Fifield, employers should provide additional consideration to any employee who signs a post-employment restrictive covenant.