This Ogletree, Deakins, Nash, Smoak & Stewart, P.C. memorandum discusses the Virginia Supreme Court's opinion in Home Paramount Pest Control Companies, Inc. v. Shaffer. In this decision, the Virginia Supreme Court held that a non-compete clause in an employment agreement was overbroad and unenforceable because it prohibited the employee from working for a competitor "in any manner whatsoever." This decision reverses long-standing precedent, under which the Virginia Supreme Court previously held that identical language was enforceable.