Ollin Star, LC v. Clemens Food Group, LLC; Country View Family Farms, LLC
June 23, 2026·25-2525·Panel Decision·By Maria Santos
The United States Court of Appeals for the Eighth Circuit affirmed a district court ruling that a non-compete covenant between a recruiting firm and an independent contractor was unenforceable under Iowa law. The appellate court found the restriction was not reasonably necessary to protect the seller's business and disproportionately burdened the contractor.
Ollin Star, LC, an Iowa recruiting firm, appealed an adverse grant of summary judgment in its diversity breach-of-contract action against Clemens Food Group, LLC and Country View Family Farms, LLC.
The court’s reasoning
Upon de novo review, the court concluded that the parties’ non-compete covenant was unenforceable under Iowa law. The court relied on the district court’s reasoning, noting that the provision was not reasonably necessary to protect the seller’s business, disproportionately burdened the contractor, and that the public interest factor did not strongly support either side.
What it means going forward
The decision reinforces that non-compete covenants in Iowa must be narrowly tailored and reasonably necessary to protect a legitimate business interest, particularly when applied to independent contractors.
