Marsh USA Inc., and Marsh & McLennan Companies, Inc., Petitioners v. Rex Cook, Respondent

Summary

The Texas Supreme Court held that a non‑solicitation covenant tied to stock options is enforceable because the consideration is reasonably related to the employer’s protectable goodwill, rejecting the Light "give rise" requirement. The Court reversed the Court of Appeals and remanded for the trial court to determine the covenant’s reasonableness. Justice GREEN dissented, arguing that stock options do not satisfy the consideration prong, and Justice WILLETT concurred in the judgment, emphasizing the need to scrutinize the covenant’s reasonableness.