Overview

• On Sept. 5, the FTC moved to dismiss appeals in Ryan, LLC v. FTC and Properties of the Villages v. FTC, with a 3–1 commission vote that included a dissent from Commissioner Rebecca Slaughter.
• On Sept. 10, the agency sent warning letters to several large health care and staffing employers urging comprehensive reviews of non-compete and other post-employment restrictions.
• The FTC launched a public inquiry on non-compete practices that is accepting submissions through Nov. 3, 2025, signaling continued oversight beyond any single rule.
• Officials highlighted case-by-case enforcement using existing authority, citing concerns about worker mobility and access to care and referencing a proposed consent order against Gateway Services, Inc.
• With the federal rule vacated, employers face a patchwork of state standards, as jurisdictions like California restrict enforcement while states such as Florida remain more receptive and places like Maryland, D.C., and Virginia impose targeted limits.