In Henshaw v. Kroenecke, 656 S.W.2d 416, 417-18 (Tex. 1983), Henshaw and Kroenecke created a two-person partnership using an agreement containing a non-compete covenant prohibiting Kroenecke from "compet[ing] with Henshaw in the business as then carried on by the partnership for a period of three years from the date of termination." Id. at 417.
The partnership agreement stated that "'competition' for the purposes of [the non-compete covenant] shall have the limited definition of providing any similar services to the then clients of the partnership or to those clients who have ceased being clients within the twelve months immediately preceding such termination." Id.
Kroenecke argued that the non-compete covenant was unreasonable and unenforceable. Id. at 418.
The court analyzed the circumstances under which the non-compete covenant was entered and held that the non-compete covenant was not unreasonable. Id.