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Civil Procedure Keyed to Yeazell
Epic Systems v. Lewis
Citation:
548 U.S. ____ (2018)Facts
Plaintiff entered into an employment contract with Defendant, providing that any disputes between the parties would be resolved through arbitration. The agreement stated that such arbitration would be on an individual basis, and could not be with a group or class of other similarly situated employees. Despite this clause, Plaintiff filed a class-action suit against Defendant claiming a violation of the Fair Labor Standards Act. Defendant filed a motion to compel arbitration, based on the employment contract. The district court granted the motion based on the Federal Arbitration Act (FAA), which provided that arbitration agreements should be enforced according to their terms. The United States Court of Appeals for the Ninth Circuit reversed based on a savings clause in the FAA. The clause provided an exception to mandatory enforcement if a party could invalidate an arbitration agreement based on “such grounds as exist at law or in equity for the revocation of any contract.” The court of appeals held that Plaintiff’s agreement violated theNational Labor Relations Act’s (NLRA) provision allowing employees to collectively bargain. The United States Supreme Court granted certiorari.
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