Justia Arbitration & Mediation Opinion Summaries

This case arose from an employee grievance at Los Alamos National Laboratory (LANL), operated by Los Alamos National Security, LLC. After succeeding in arbitration, the employee, John Horne, filed a lawsuit in state district court in 2008, in which he alleged more expansive claims arising out of the same subject matter covered in the arbitration agreement. LANL objected, claiming that it should not have to defend against claims that either were subject to arbitration or were waived by the arbitration agreement. The Supreme Court took the opportunity of this case opinion to discuss the consequences that follow when an employee voluntarily contracts to arbitrate grievances and what the employee must do to preserve a subsequent lawsuit if that is his intention. In this case the Court sided with the district court's ruling in favor of LANL, and reversed the Court of Appeals. View "Horne v. Los Alamos Nat'l Sec., L.L.C." on Justia Law

Bristol Care appealed the denial of its motion to compel arbitration in a suit initiated by its former employee asserting claims under the Fair Labor Standards Act (FLSA), 29 U.S.C. 201 et seq., and seeking class action certification. Given the absence of any contrary congressional command from the FLSA that a right to engage in class actions overrides the mandate of the Federal Arbitration Act, 9 U.S.C. 3-4, in favor of arbitration, the court held that arbitration agreements containing class waivers were enforceable in claims brought under the FLSA. Because the court concluded that the Mandatory Arbitration Agreement (MAA) signed by the employee and Bristol Care was enforceable, the court reversed the district court's decision and directed the district court to enter an order granting Bristol Care's motion to stay proceedings and compel arbitration. View "Owen v. Bristol Care, Inc." on Justia Law

Blue Cross and Blue Shield of Montana (BCBS) signed an employment agreement with Plaintiff containing a clause to compel arbitration for any disputes regarding the employment agreement. After Plaintiff's employment was terminated, Plaintiff brought an action against BCBS claiming that BCBS violated the Wrongful Discharge from Employment Act (WDEA). Plaintiff, however, could bring a WDEA claim only if she did not have a written contract of employment for a specific term. The district court compelled arbitration to allow the arbitrator to determine in the first instance whether Plaintiff had a term employment contract. The Supreme Court affirmed the district court's order to compel arbitration, holding that because the instant dispute implicated the terms or provisions of the employment agreement, the district court correctly determined that an arbitrator should decide, in the first instance, whether Plaintiff was an at-will employee or whether she had a term contract. View "Marsden v. Blue Cross & Blue Shield of Mont., Inc." on Justia Law

This appeal involved litigation between Coverall North America, Inc. and its franchisees. Proceeding under federal diversity jurisdiction, the franchisees asserted a variety of state-law claims against Coverall. Which of the various plaintiffs were subject to the arbitration provisions of the Franchise Agreement was at issue in this appeal. Appellees were a subgroup of Plaintiffs who became Coverall franchisees by signing consent to transfer agreements, which by reference incorporated under franchise agreements that contained arbitration clauses. The district court determined that Appellees did not have to arbitrate their claims against Coverall because they did not have adequate notice of the arbitration clauses contained in the franchise agreements. The First Circuit Court of Appeals reversed, holding that the district court erred because (1) Massachusetts law, which governed this dispute, did not impose any such special notice requirement upon these commercial contractual provisions; and (2) in any event, any special notice requirement would be preempted by the Federal Arbitration Act. View "Awuah v. Coverall N.A., Inc. " on Justia Law

Illini Concrete formally ceased doing business in October 2009 and sold certain of its assets, including delivery trucks, to Kienstra. The Teamsters Local Union, which represents concrete mixer drivers and others employed by Illini and then by Kienstra, alleged that Kienstra laid off 14employees, declined to make good on Illini’s unfunded liability to its employees’ union pension fund, subcontracted work to competitors to avoid hiring back union employees,and refused to hear grievances regarding the asset sale and its effect on the employees. The Union claimed that the asset sale was a ruse to allow Illini to evade obligations under its collective bargaining agreement and sought a declaration that Kienstra is Illini’s alter ego, bound by the CBA. The district court denied motions to compel arbitration. Kienstra and Illini Concrete filed an interlocutory appeal. The Seventh Circuit dismissed for lack of appellate jurisdiction, citing the Federal Arbitration Act, 9 U.S.C. 1, which states that “nothing [in the FAA] shall apply to contracts of employment of seamen, railroad employees, or any other class of workers engaged in foreign or interstate commerce.” View "Int'l Bhd. of Teamsters, Local Union No. 50 v. Kienstra Precast, LLC" on Justia Law

Nitro-Lift contracts with operators of oil and gas wells to provide services. Howard and Schneider entered a confidentiality-noncompetition agreement with Nitro-Lift that contained an arbitration clause” After working for Nitro-Lift on wells in Oklahoma, Texas, and Arkansas, they quit and began working for one of Nitro-Lift’s competitors. Nitro-Lift served them with a demand for arbitration. The former employees filed suit Oklahoma, asking the court to declare the agreements void and enjoin enforcement. The court dismissed. The Oklahoma Supreme Court ordered the parties to show cause why the matter should not be resolved by application of Okla. Stat., Tit. 15, 219A, which limits the enforceability of noncompetition agreements. Nitro-Lift argued that any dispute as to the contracts’ enforceability was a question for the arbitrator. The Oklahoma Supreme Court held that the existence of an arbitration agreement in an employment contract does not prohibit judicial review of the underlying agreement. The U.S. Supreme Court vacated, holding that the state court misconstrued the Federal Arbitration Act, 9 U.S.C. 1, which favors arbitration. View "Nitro-Lift Techs., L.L.C. v. Howard" on Justia Law

Paul brought state law claims for disability discrimination and retaliation against her former employer after her 12-year employment as a CT Technologist came to an end following a work-related injury. The employer removed the action to federal court on the basis of complete preemption under the Labor Management Relations Act, contending plaintiff’s claims implicated rights under the collective bargaining agreement, which included a mandatory arbitration requirement. The district court denied remand to state court and dismissed for failure to submit to mandatory arbitration. The Sixth Circuit vacated. Although plaintiff’s claim of unlawful discrimination in the terms and conditions of employment by refusing to reasonably accommodate her disability implicates an employment relationship created and defined by the Collective Bargaining Agreement, the employer did not demonstrate that resolution of the claim is so “inextricably intertwined” with interpretation of CBA terms as to trigger complete preemption. View "Paul v. Kaiser Found. Health Plan of OH" on Justia Law

Plaintiff filed a Title VII discrimination suit against his employer, the Department of Homeland Security. At issue on appeal was whether the parties had reached an enforceable settlement. The court concluded that the district court did not abuse its discretion by finding that plaintiff was bound by the terms of his attorney's settlement offer. Further, the court never held that the Fifth Amendment's due process guarantee was implicated by defective representation in Title VII proceedings and plaintiff had introduced no evidence to suggest that his attorney's representation was less than competent. View "Quesada v. Napolitano" on Justia Law

This insurance coverage dispute arose from charges of sexual harassment brought by a one-time employee against Appellant, the former president of Jasmine Company, Inc. Appellant sought a defense to and indemnity for the harassment claims from Appellee, Jasmine's liability insurance provider. The district court ruled that Appellant was not entitled to coverage from Appellee because, under the doctrine of issue preclusion, a prior arbitration between Appellant and the purchaser of his business conclusively established that Appellant's conduct fell within an exclusion to Appellee's insurance policy. The First Circuit Court of Appeals affirmed, holding (1) the arbitration presented Appellant with the full and fair opportunity for adjudication on the issue at hand; and (2) therefore, the district court was correct to bar Appellant from disputing the applicability of the exclusion based on the doctrine of issue preclusion. View "Manganella v. Evanston Ins. Co." on Justia Law

A collective-bargaining agreement between Baltimore County and Baltimore County Fraternal Order of Police, Lodge 4 (FOP) contained an arbitration clause and a retiree health-insurance provision. FOP believed the provision locked in place the health-insurance subsidy as it existed at the time of an officer's retirement. After the agreement expired and the County decreased the health-insurance subsidy, FOP initiated arbitration. The County protested, arguing (1) it had no duty to arbitrate because the collective-bargaining agreement had expired, and (2) the health-insurance subsidy was not locked in place but was subject to change from year to year. FOP was successful in arbitration and on appeal before the circuit court, but the court of special appeals vacated the arbitration award. The Court of Appeals reversed, holding (1) an arbitration clause may survive the expiration of a collective bargaining agreement when it concerns rights that vested during the life of the agreement; and (2) when deciding the issue of arbitrability requires interpretation of the underlying agreement and consideration of the merits of the dispute, the issue of arbitrability should initially be determined by the arbitrator. View "Baltimore County Fraternal Order of Police Lodge v. Baltimore County" on Justia Law