Purchasing Associates, Inc. v. Weitz

In Purchasing Associates, Inc. v. Weitz (13 NY2d 267 [1963]), the Court explained that "W}e must look behind and beyond the label to ascertain the true nature of the transaction" (see id. at 273). In that case, the Court noted that the defendant against whom the non-compete agreement was to be enforced: "could not have transferred any. . . customers or good will in the . . . business, as the record itself demonstrates, neither he nor his partnership was in that business and had no customers at the time of the deal. He was merely a salaried employee of {the business}." The Court went on to state unequivocally that the standard for evaluating the enforceability of employer/employee employment agreements applied.