This and potentially using confidential info/IP/trade secrets gleaned or taken (those provisions are still in covenant agreements but pretty hard to prove a breach). But the Supreme Court will overturn it because of the Chamber of Commerce and other lobbies.
I have been dealing with candidates who have what I call a tradition non-compete (you can't go work for a competitor for a period of time), for well over a decade and have yet to be in a position where a company has actually litigated to enforce it - they just use it as leverage to get an agreement that other covenants (primarily client non-solicits) will be followed. My company has client/employee non-solicits (which should remain enforceable unless they are unreasonably broad), but not a traditional non-compete, and most companies are moving away from traditional non-competes given state movement to ban or limit them in any event.
