PCC Airfoils, LLC v. Justin Daugherty

── PCC Airfoils, LLC v. Justin Daugherty ── Court: Court of Appeals for the Sixth Circuit Date: May 19, 2026 Category: General RECOMMENDED FOR PUBLICATION Pursuant to Sixth Circuit I.O.P. 32.1(b) File Name: 26a0149p.06 UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT ┐ PCC AIRFOILS, LLC, │ Plaintiff-Appellant, │ > No. 25-3794 │ v. │ │ JUSTIN DAUGHERTY; CONSOLIDATED PRECISION │ PRODUCTS CORP., │ Defendants-Appellees. │ ┘ Appeal from the United States District Court for the Northern District of Ohio at Cleveland. No. 1:25-cv-00917—Bridget Meehan Brennan, District Judge. Argued: April 29, 2026 Decided and Filed: May 19, 2026 Before: SUTTON, Chief Judge; DAVIS and RITZ, Circuit Judges. _________________ COUNSEL ARGUED: Michael P. Elkon, FISHER & PHILLIPS LLP, Atlanta, Georgia, for Appellant. Phil Eckenrode, BENESCH, FRIEDLANDER, COPLAN & ARONOFF LLP, Cleveland, Ohio, for Appellees. ON BRIEF: Michael P. Elkon, Nicole Holtzapple, FISHER & PHILLIPS LLP, Atlanta, Georgia, Russell Beck, BECK REED RIDEN, Boston, Massachusetts, for Appellant. Phil Eckenrode, W. Eric Baisden, BENESCH, FRIEDLANDER, COPLAN & ARONOFF LLP, Cleveland, Ohio, James M. Drozdowski, Joseph A. Nero, Nancy A. Oliver, KAUFMAN, DROZDOWSKI & GRENDELL, LLC, Pepper Pike, Ohio, for Appellees. _________________ OPINION _________________ SUTTON, Chief Judge. After working for 26 years as an engineer at PCC Airfoils, Justin Daugherty accepted an offer to become the director of engineering at one of PCC’s competitors.  No. 25-3794 PCC Airfoils, LLC v. Daugherty et al. Page 2 PCC alleges that Daugherty printed several documents containing trade secrets on his way out the door. It sued and sought a preliminary injunction to prevent Daugherty from disclosing the trade secrets or working on products similar to the ones he worked on while at PCC. The district court denied the request. Relying on existing district court precedents, the court explained that PCC failed to meet each of the preliminary injunction factors with “clear and convincing” evidence. But that approach runs counter to our test for preliminary injunctions. Rather than requiring clear and convincing evidence for each preliminary injunction factor, a court should consider all four factors to determine whether, taken together, they clearly weigh in favor of granting injunctive relief. We reverse and remand. I. In 1998, Daugherty began working at PCC, where he developed the company’s industrial gas turbine airfoils. In 2020, PCC rewarded his decades of work by promoting him to be the director of engineering. Within a year, however, the company went through a restructuring and stripped Daugherty of his new title and responsibilities. Daugherty expressed frustration about the demotion and the lack of promotional opportunities. But nothing changed. Daugherty began to think about leaving PCC. When he received an offer to become the director of engineering at Consolidated Precision Products, one of PCC’s competitors, Daugherty took it. Daugherty did not have a non-compete agreement with PCC. After Daugherty submitted