In 2016, The New York Times estimated that 30 million working Americans, or about one in five employed citizens, are subject to “non-compete agreements” (“To Compete Better, States are Trying to Curb Noncompete Pacts,” N.Y. Times, June 28, 2016). These agreements between an employer and a worker limit the worker’s ability to work after he leaves his employer, whether through being laid off, termination or resignation.