PCC AIRFOILS, LLC, v. JUSTIN DAUGHERTY; CONSOLIDATED PRECISION PRODUCTS CORP. - Articles

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PCC AIRFOILS, LLC, v. JUSTIN DAUGHERTY; CONSOLIDATED PRECISION PRODUCTS CORP.

Posted by: Azya Thornton on May 19, 2026

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ARGUED: Michael P. Elkon, FISHER & PHILLIPS LLP, Atlanta, Georgia, for Appellant.

Attorneys 2: ARGUED: Phil Eckenrode, BENESCH, FRIEDLANDER, COPLAN & ARONOFF LLP, Cleveland, Ohio, for Appellees.

Attorneys 3: ON BRIEF: Michael P. Elkon, Nicole Holtzapple, FISHER & PHILLIPS LLP, Atlanta, Georgia, Russell Beck, BECK REED RIDEN, Boston, Massachusetts, for Appellant.

Attorneys 4: ON BRIEF: 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.

Judge(s): SUTTON, Chief Judge; DAVIS and RITZ, Circuit Judges

Court Appealed: United States District Court for the Northern District of Ohio at Cleveland

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. 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.

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