The Eighth Circuit Court of Appeals is reviewing a preliminary injunction issued in a high-stakes employment dispute involving the mass exodus of financial advisors from a national investment firm to a competitor.
In *Choreo, LLC v. Kevin Lors* (8th Cir. 2026), the appeals court is examining a district court's decision to grant a sweeping preliminary injunction against former Choreo employees and their new employer, Compound Planning, following allegations of contract breaches and trade secret theft.
The case stems from events in January 2025, when four senior financial advisors—Kevin Lors, Aaron Schomer, Joleen Scheer, and Lindsey O'Neil—resigned from Choreo's Des Moines branch and joined Atomi Financial Group, Inc., doing business as Compound Planning. The competing investment advisory firm was opening a new Des Moines office at the time.
The departures did not stop there. Within weeks of the four senior advisors leaving, eight of the nine remaining Choreo financial advisors in Des Moines resigned in unison and also joined Compound Planning. This left Choreo with only one advisor remaining at what had been a 13-person branch office.
According to court documents, Compound Planning offered the departing advisors "lavish incentives" to continue serving their former clients, despite restrictive covenants in the advisors' employment contracts with Choreo that were designed to prevent such client solicitation.
Choreo responded swiftly to the mass departures, filing a federal lawsuit in the U.S. District Court for the Southern District of Iowa. The complaint alleged multiple legal violations against the departing employees and their new employer.
Against the four senior advisors, Choreo claimed breach of three separate restrictive covenants contained in their employment agreements. These covenants typically include non-compete clauses, non-solicitation agreements, and confidentiality provisions designed to protect the firm's business relationships and proprietary information.
Choreo also sued Compound Planning for tortious interference with contract, alleging that the competing firm knowingly induced the advisors to breach their contractual obligations to Choreo. This claim suggests that Compound Planning was aware of the restrictive covenants but proceeded to recruit the advisors anyway.
Additionally, the lawsuit includes trade secret theft allegations under both federal and Iowa state law against all defendants. Trade secrets in the financial advisory context often include client lists, investment strategies, proprietary analytical tools, and detailed client financial information that competitors could use to gain unfair advantages.
The district court sided with Choreo, granting the firm's motion for a preliminary injunction. According to the Eighth Circuit's opinion, this injunction was described as "sweeping," suggesting it imposed broad restrictions on the defendants' ability to compete or serve former Choreo clients.
Preliminary injunctions are extraordinary remedies that courts grant before a full trial on the merits. To obtain such relief, plaintiffs must typically demonstrate they are likely to succeed on the merits, face irreparable harm without the injunction, and that the balance of hardships favors granting the injunction.
The defendants appealed the preliminary injunction to the Eighth Circuit, which has jurisdiction to review such interlocutory orders under federal law. The appeals court submitted the case for decision in September 2025 and issued its opinion on Jan. 12, 2026.
In the opinion excerpt available, Circuit Judge Loken, writing for a three-judge panel that also included Circuit Judges Kelly and Erickson, noted the fundamental principle underlying injunctive relief in federal courts. "The basis of injunctive relief in the federal courts has always been irreparable harm and inadequacy of legal remedies," the court wrote, citing established precedent.
This language suggests the Eighth Circuit will closely examine whether Choreo demonstrated the irreparable harm necessary to justify the broad preliminary injunction granted by the district court.
The case highlights ongoing tensions in the financial services industry over employee mobility and client relationships. Investment advisory firms invest significant resources in training advisors and building client relationships, leading to employment agreements with restrictive covenants designed to protect these investments.
However, financial advisors often argue these restrictions limit their ability to serve clients and advance their careers, particularly when they believe they can provide better service at competing firms.
The outcome of this appeal could influence how courts balance these competing interests in future employment disputes within the financial services sector. It may also provide guidance on what constitutes appropriate preliminary injunctive relief in cases involving mass employee departures and allegations of trade secret misappropriation.
The full text of the Eighth Circuit's decision was not immediately available, leaving questions about whether the appeals court affirmed, reversed, or modified the district court's preliminary injunction. The resolution of this case will likely impact both the immediate parties and broader industry practices regarding advisor recruitment and employment restrictions.