This Law Firm Publication by Epstein Becker & Green, P.C. discusses the Wisconsin Supreme Court's recent decision in Manitowoc Company v. Lanning, in which it held that Wisconsin's non-compete statute (Wis. Stat. s. 103.465), broadly applies to post-employment restrictions on the ability to solicit former co-workers. Specifically the Wisconsin Supreme Court held that a non-solicitation clause prohibiting a former employee of the plaintiff, within the two-year period following his resignation, from soliciting or inducing any current employees to join a competitor was an unreasonable restraint on trade which failed to meet the requirement under Section 103.465 that the restriction "be reasonably necessary for the protection of the employer."