By Christopher Hennessy and Jeremy Glenn (September 11, 2018, 12:23 PM EDT) -- Every election year, there is talk of "red states" and "blue states" as they relate to political parties. Within the context of restrictive covenants in employment agreements, there are also "red" and "blue" states, with the color a reference to the doctrine courts apply in that state when enforcing those agreements. The difference between "red" and "blue" is significant in the election context, and many predictions as to the outcome of an election are tied directly to the color historically connected to that state. The difference is also significant enough in employment agreements to make or break a restrictive covenant case. As with elections, states that are not so clearly connected to red or blue make the outcome more difficult to predict. At the same time, a recent case from the Northern District of Illinois showcases the continual challenges that employers face across the country....