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Legislation and Regulation Keyed to Manning, 5th Ed.
Circuit City Stores, Inc. v. Adams
Citation:
532 U.S. 105 (2001)Facts
In October 1995, Saint Clair Adams applied for a job at Circuit City Stores, a national retailer of consumer electronics. The employment application he signed contained a clause requiring him to settle all employment-related disputes exclusively through binding arbitration. Adams was hired as a sales counselor at Circuit City’s store in Santa Rosa, California. Two years later, Adams filed an employment discrimination lawsuit against Circuit City in state court, asserting claims under California’s Fair Employment and Housing Act and other state tort claims. Circuit City responded by filing suit in federal district court seeking to enjoin the state court action and compel arbitration pursuant to the FAA. The district court ruled in favor of Circuit City, but while Adams’ appeal was pending, the Ninth Circuit ruled in another case (Craft v. Campbell Soup Co.) that the FAA does not apply to contracts of employment. Following this precedent, the Ninth Circuit held that the arbitration agreement between Adams and Circuit City was contained in a “contract of employment” and thus exempt from the FAA.
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