GE Betz, Inc. v. Moffitt-Johnston, 2018

In the 2018 case of GE Betz, Inc. v. Moffitt-Johnston, the
United States Court of Appeals for the Fifth Circuit dealt with
allegations from GE Betz, Inc. against Michelle Moffitt-Johnston
and AmSpec Services, L.L.C. for breaching a non-solicitation
agreement, misappropriating trade secrets, and tortiously
interfering with prospective business relationships. The district
court partially granted summary judgment in favor of the
defendants, particularly dismissing the trade secret
misappropriation claim due to speculative evidence. The
appellate court affirmed this decision in part but vacated the
award of $217,189 in attorney’s fees to Moffitt-Johnston,
finding insufficient evidence of breach of the non-solicitation
agreement or trade secret misappropriation. This case
underscores the importance of concrete evidence in claims of
trade secret misappropriation and contractual breaches. The
decision is an appeal from the district court for the Southern
District of Texas.