Veterinary Non-Competes in Missouri

Missouri has no general statute governing employee non-competes, so a veterinarian's covenant is measured against the common-law standard the Missouri Supreme Court restated in Whelan Security Co. v.

Kennebrew: a non-compete agreement must be narrowly tailored temporally and geographically and must seek to protect legitimate employer interests beyond mere competition by a former employee, and it is enforceable only to the extent the restrictions protect the employer's trade secrets or customer contacts.

The employer, not the departing veterinarian, carries the burden of proving both that the agreement protects one of those legitimate interests and that its time and geographic limits are reasonable.

Read against an offer, that means the covenant is tested against what the practice is actually protecting rather than against a fixed statutory number of months or miles.

Missouri has not enacted a healthcare-practitioner non-compete statute.

The one development in this area, HB 2184, was introduced for the 2026 legislative session and would void non-compete restrictions for licensed physicians — it names physicians only, not veterinarians, and a Midpage full-text search of the current Revised Statutes of Missouri finds no codified physician non-compete provision, confirming the bill has not been enacted.

A veterinarian who has read about Missouri restricting healthcare non-competes should not assume any such law reaches their own employment contract: as of the sources read for this page, HB 2184 remains a bill, not law.

Missouri's common-law reasonableness test contains no wage or salary threshold, so the same standard applies whatever a veterinarian earns.

It also has no fixed statutory duration cap: Whelan Security Co. v.

Kennebrew requires a covenant to be narrowly tailored temporally and geographically to the employer's trade secrets or customer contacts, rather than measured against a set number of months or miles.

A veterinarian's actual duration and geographic limits are tested against that standard, not against a fixed number.

Whelan Security Co. v.

Kennebrew holds that when a non-compete clause imposes a restraint that is unreasonably broad, an appellate court can still give effect to the covenant's purpose by refusing to give effect to the unreasonable terms or by modifying the terms of the contract to be reasonable.

That describes a court reworking the covenant's own terms rather than either enforcing it exactly as written or voiding it entirely.

For a veterinarian reviewing a covenant with a long duration or a wide radius, that means an overbroad clause is not necessarily the end of the covenant — the case does not, however, say which terms a court will choose to keep, strike, or rewrite in a given contract.

Mo.

Rev.

Stat. § 431.202 is frequently mis-cited as Missouri's non-compete statute, but its own text says otherwise: subsection 3 provides that nothing in subdivision (3) or (4) of subsection 1 is intended to create, or to affect the validity or enforceability of, employer-employee covenants not to compete.

What § 431.202 covers is narrower still — subsection 1 reaches only a covenant against soliciting, recruiting, hiring, or interfering with the employment of the employer's own employees, not a covenant restricting solicitation of the practice's customers, and not the non-compete restriction on where a veterinarian can work.

It reaches four scenarios: covenants tied to a merger or acquisition, a joint venture, an employer's protectable interest in trade secrets or customer relationships, and a general employee non-solicitation covenant excluding clerical or secretarial staff.

Only the latter two get a conclusive one-year-or-less presumption of reasonableness — the merger and joint-venture covenants are judged on the facts and circumstances instead.

A veterinarian's actual non-compete is governed by the separate common-law reasonableness test, not by this section.

The research behind this page establishes the common-law reasonableness test, the reformation approach to an overbroad covenant, and the scope of the § 431.202 non-solicitation safe harbor, but it does not establish how Missouri treats a covenant tied to selling a veterinary practice or an ownership interest.

That gap matters most at a buy-in or buy-out, where a covenant may be drafted alongside the purchase terms rather than the employment terms.

It is left blank here rather than filled from another state's rule or from the near-universal pattern that a sale-related covenant is treated more permissively — take it to a Missouri attorney with the whole agreement in hand.