Employment Law Questions? Ask an Employment Lawyer.
Customer lists are not information that can be considered proprietary information and thus aren't protected by the law. In other words, if you can find the person's information in a phone book, it is not misappropriation of a trade secret. Now, if the employee took for example patient records or other information that was created as work product, that could be considered misappropriation and unfair competition. Otherwise there is no valid claim to be made.