Equal Employment Opportunity Commission v. Waffle House, Inc.

Employment agreement providing for arbitration of employment-related disputes did not bar EEOC from pursuing victim-specific judicial relief in enforcement action under Americans with Disabilities Act.

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The full case caption appears at the end of this opinion.

Respondent’ s employees must each sign an agreement requiring employment disputes to be settled by binding arbitration. After Eric Baker suffered a seizure and was fired by respondent, he filed a timely discrimination charge with the Equal Employment Opportunity Commission (EEOC) alleging that his discharge violated Title I of the Americans with Disabilities Act of 1990 (ADA). The EEOC subsequently filed this enforcement suit, to which Baker is not a party, alleging that respondent’ s employment practices, including Baker’ s discharge “because of his disability,” violated the ADA and that the violation was intentional and done with malice or reckless indifference. The complaint requested injunctive relief to “eradicate the effects of [respondent' s] past and present unlawful employment practices” ; specific relief designed to make Baker whole, including backpay, reinstatement, and compensatory damages; and punitive damages for malicious and reckless conduct. Respondent petitioned under the Federal Arbitration Act (FAA) to stay the EEOC’ s suit and compel arbitration, or to dismiss the action, but the District Court denied relief. The Fourth Circuit concluded that the arbitration agreement between Baker and respondent did not foreclose the enforcement action because the EEOC was not a party to the contract, but had independent statutory authority to bring suit in any federal district court where venue was proper. Nevertheless, the court held that the EEOC was limited to injunctive relief and precluded from seeking victim-specific relief because the FAA policy favoring enforcement of private arbitration agreements outweighs the EEOC’ s right to proceed in federal court when it seeks primarily to vindicate private, rather than public, interests.

Equal Employment Opportunity Commission v. Waffle House, Inc.

Employment agreement providing for arbitration of employment-related disputes did not bar EEOC from pursuing victim-specific judicial relief in enforcement action under Americans with Disabilities Act.

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