In WellSpan Health v. Bayliss, the WellSpan Health System, the primary components of which are York Hospital and Gettysburg Hospital, attempted to enforce a restrictive covenant against a physician in all counties listed in the non-compete section of an employment contract, despite the fact that WellSpan had no physical presence in three of the counties. The trial court enforced the restrictive covenant by enjoining Dr. Bayliss from practicing in York and Adams counties, but not Lancaster County. The Superior Court affirmed the trial court, affirmed that restrictive covenants are enforceable when reasonably designed to protect identifiable interests, but also acknowledged the necessity to balance the public interest involved.
