In California and Texas, covenants not to compete are generally unenforceable, while non-compete agreements are generally enforceable in Washington State. What makes a non-compete agreement unenforceable in Washington State is when there is no independent consideration given at the time the agreement is reached. In Labriola vs. Pollard Inc., Labriola signed a non-compete agreement when he was hired by Pollard in 1997, in which Pollard restricted Labriola from competing for certain customers...