By Leonard Samuels (October 11, 2017, 10:50 AM EDT) -- Many businesses throughout Florida rely heavily, if not exclusively, upon referral sources to obtain business. Many of these same business require their sales force to sign noncompetes to protect their customers, accounts and referral sources from unfair competition. A noncompete in Florida is valid and enforceable only if supported by a legitimate business interest, Section 543.335(1), of the Florida statutes. Prior to the Sept. 14, 2017, Florida Supreme Court decision in the consolidated cases of White v. Mederi Caretenders Visiting Services of Southeast Florida LLC et al., case number SC16-28, and Americare Home Therapy Inc. v. Hiles, case number 16-400, there was a split in the lower courts as to whether referral sources were a legitimate business interest sufficient to support enforcement of noncompete agreements. In White, the Supreme Court rectified the conflict and unanimously held that referral sources are worthy of protection, dependent upon the facts of the case and the industry involved....