This Law Firm Publication by Epstein Becker & Green, P.C. discusses the Illinois Appellate Court for the Third District's decision in Prairie Rheumatology Associates, S.C. V. Maria Francis, D.O. This is the first Illinois appellate court to address the 2013 decision in Fifield v. Premier Dealer Services, Inc., which stated that at least two years of employment is required to constitute adequate consideration in support of a restrictive covenant, even if the employee voluntarily resigns. In Prairie Rheumatology, an employee who resigned after 19 months of employment successfully challenged her employer's efforts to enforce her non-compete agreement. Since she had been employed for less than two years and had not received other adequate consideration, the appellate court strictly adhered to Fifield, holding that the non-compete was unenforceable.