Appeals Court Backs Stryker in Ridgeway “Poaching” Case
Walter Eisner • Fri, June 9th, 2017
The long road for redemption for former Stryker Corporation sales rep Christopher Ridgeway is not ending well for him.
On May 25, 2017, MassDevice reported that the U.S. Court of Appeals for the 6th Circuit sided with Stryker after Ridgeway appealed a lower court ruling in the company's favor.
In 2013, Stryker sued and accused Ridgeway and Biomet, Inc. of poaching Ridgeway and Stryker reps in New Orleans to join Biomet. Stryker also accused Ridgeway of running other medical device supply businesses on the side in Louisiana.
We wrote extensively about this story in October 2013.
Ridgeway countersued, claiming that Stryker did not have a non-compete agreement with him and offered evidence that the company had fabricated his signature on a fake non-compete agreement. He said the company defamed him by telling customers that he had a non-compete agreement, costing him millions.
The case went to trial in a federal court in Stryker's home state of Michigan. In February 2016, a federal jury found for the company and awarded Stryker $745,195 in damages on three counts: breach of contract, breach of fiduciary duty and a trade-secrets claim.
Ridgeway appealed to the U.S. Court of Appeals for the 6th Circuit. He said the district judge made a mistake by not allowing two privileged emails showing Stryker knew Ridgeway had no non-compete agreement to be introduced as evidence at the trial.
Ridgeway also argued that the case should have been tried in a federal court in Louisiana where the alleged actions took place.
Judge Julia Smith Gibbons, writing for a three-judge panel, found that the lower court was correct to apply Michigan law, as that state’s interest in the case trumps Louisiana’s.
Gibbons also supported the lower court’s exclusion of the pair of emails which Ridgeway alleged showed that Stryker engaged in fraud by allegedly filing a non-compete form he never signed.
She wrote, “Ridgeway offered no other evidence to demonstrate that the agreement attached to the complaint was not his, and therefore that Stryker’s statement that it was a ‘true and correct copy’ was false. Nor did Ridgeway offer any further evidence of fraudulent activity. The law does not permit Ridgeway to rely on the emails themselves to prove the fraud. The district court did not require Ridgeway to unequivocally prove the fraud but instead asked for some evidence to establish a reasonable basis for believing that fraud occurred. Because Ridgeway did not make such a showing, the district court did not abuse its discretion by rejecting Ridgeway’s crime-fraud-exception argument.”
This might be the end of the road of a very high-profile case that gave the public insight into the fierce competition between device companies for sales representatives in an industry during a time of consolidation. Ridgeway's legal options are now limited to appealing to the last court of appeals—the U.S. Supreme Court.