had to be reasonable and limited. In Samuel Stores, Inc. v. Abrams, 94 Conn. 248, 108 A.541 (1919), the Connecticut Supreme Court affirmed a ruling by a lower court denying an attempt by a clothing store to enforce such a covenant against a clothing store manager for five years in any city in which the employer did business. In that case at 543, the Court posed the test as to whether the "restriction is reasonably necessary for the protection of the plaintiff's business" and concluded at 544 that it was "a useless, unnecessary, and undue curtailment of the defendant's liberty of trading and employment, and an unjustifiable restraint on competition." The Court emphasized at 543 that a clothing store manager did not provide services which were "peculiar or individual in their character, nor purely intellectual, nor . . . special or extraordinary."
Modern Trends. Since the Samuel Stores case, the Connecticut courts have well nigh universally enforced such covenants. See Torrington Creamery v. Davenport, 126 Conn. 515, 12 A.2d 780 (1940), in which a two year restrictive covenant which was limited to specified towns was enforced and May v. Young, 2 A.2d 385 (1938 Sup. Ct.) in which the denial by a lower court for an injunction to enforce a t
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