This Law Firm Publication by Epstein Becker Green discusses the Colorado Court of Appeals recent decision in Crocker v. Greater Colorado Anesthesia, P.C. in which the court held that under Colorado statute Section 8-2-113 (Colo. Rev. Stat. Ann. s. 8-2-113), a liquidated damages clause in a physician non-compete agreement was not enforceable because the liquidated damages were not reasonably related to the injury actually suffered.