In Wyoming, non-compete agreements are legal and enforceable, but only if they are reasonable in scope, time, and geography and protect a legitimate business interest. The most important recent change came in 2024: the Wyoming Supreme Court, in Hassler v. Circle C Resources, held that Wyoming courts will no longer rewrite or "blue-pencil" an overly broad non-compete to make it enforceable. If a covenant not to compete is unreasonable, the entire agreement is void, and the court will not trim it down to a reasonable version. This makes Wyoming friendlier to workers than many people assume, because an employer who overreaches can lose the protection completely rather than have a judge fix it.
Wyoming's Reasonableness Test
Wyoming has no statute that broadly bans or specifically authorizes non-competes for ordinary employees. Instead, enforceability is governed by common law developed by the Wyoming Supreme Court. Under the leading case Hopper v. All Pet Animal Clinic and the Restatement (Second) of Contracts § 188, a non-compete is valid only if it meets all of the following:
- It is in writing and part of an employment contract.
- It is supported by reasonable consideration (something of value given in exchange).
- It is reasonable in duration and geographic area.
- It is no greater than necessary to protect the employer's legitimate interest.
- It does not impose undue hardship on the employee.
- It is not injurious to the public.
Legitimate business interests typically include protecting trade secrets, confidential client information, and customer relationships, or recouping specialized training. A restraint designed simply to keep a former worker from competing, with no protectable interest behind it, will not stand.
What Counts as "Reasonable" Time and Geography
There is no fixed statutory number of months or miles in Wyoming. Courts judge reasonableness case by case. A short restriction (often a year or so) covering the area where the employer actually does business and the specific role the employee held is more likely to be upheld. A multi-year, statewide, or industry-wide ban with no tie to the employer's real market is far more likely to be struck down. Because Wyoming is a large, sparsely populated state, a geographic limit that might be reasonable elsewhere can be challenged as overbroad here.
The 2024 Change: No More Blue-Penciling
For decades, Wyoming courts could "blue-pencil" a non-compete, meaning a judge could modify an unreasonable term, such as cutting a five-year ban to one year, and then enforce the narrowed version. In Hassler v. Circle C Resources (2024), the Wyoming Supreme Court reversed course and rejected that approach. Now, if a non-compete is unreasonable as written, the court will not save it by reforming it. The whole covenant fails.
This matters in two ways. First, it raises the stakes for employers, who now have a strong incentive to draft narrow, defensible agreements rather than overreach and rely on a judge to fix it. Second, it gives employees more leverage: if your non-compete is plainly overbroad, the entire restriction may be unenforceable, not just trimmed. Always have the actual language reviewed, because the outcome depends heavily on the specific wording.
Low-Wage Workers and Special Categories
Unlike states such as California (which bans most non-competes outright) or Illinois, Colorado, and Washington (which void non-competes below set wage thresholds), Wyoming has not enacted a statutory wage floor below which non-competes are automatically void. In Wyoming, the same common-law reasonableness analysis applies regardless of pay. That said, a worker's low earnings and limited bargaining power are relevant to the "undue hardship" and "public policy" parts of the test, so a sweeping non-compete imposed on a low-wage employee may be harder for an employer to justify.