Virginia Lawyer’s Weekly has an article here on a delivery dispatcher who won a noncompete suit in Fairfax Circuit Court.  The Court struck down the noncompete as overbroad under the “janitor” rule — i.e. the noncompete would have prohibited the former employee from working even as a janitor at a competitor.  the Court also refused to apply a provision in the agreement allowing the Court to modify the agreement, finding that Virginia disfavors such “blue pencil” provisions.