This Law Firm Publication by Ogletree, Deakins, Nash, Smoak & Stewart, P.C. discusses Durrell v. Tech Electronics, Inc., in which a former at-will employee filed a suit requesting that the US District Court for the Eastern District of Missouri deem invalid a non-compete agreement with his former employer. On the employer's motion to dismiss, the court concluded that at-will employment is not sufficient consideration for a non-compete, because the employer offers nothing other than the employment itself, which can be terminated for any reason. A valid non-compete in Missouri requires an employer to provide further consideration beyond the at-will employment. In reaching this decision, the court relied on several Missouri cases that held that at-will employment was not valid consideration in the arbitration agreement context. The publication instructs employers to construct non-competes and arbitration agreements with great care to avoid contracts that can be found invalid.