As ocdtrekkie pointed out, the key point here is he was soliciting former colleagues while there were still current colleagues. Even California won't protect you there.

The one tool companies have at their disposal in CA is the prohibition of using your old company's trade secrets in your new job. Mostly that means you can't take customer lists with you, but you also can't use confidential information to lure away former colleagues.

What that means in practice isn't completely clear to me, though it may just be that you can't take the org chart.

EDIT: http://www.rhdtlaw.com/job-hopping-california-right/