McLeod v. General Mills, Inc., No. 15-3540 (8th Cir. 2017)Annotate this Case
General Mills terminated employees and offered them benefits in exchange for releasing all Age Discrimination in Employment Act (ADEA), 29 U.S.C. 626(f)(1), claims and arbitrating release-related disputes. Plaintiffs, 33 employees who signed releases, subsequently filed suit seeking a declaratory judgment that the releases were not "knowing and voluntary." Plaintiffs also raised collective and individual ADEA claims. The district court denied General Mills' motion to compel arbitration. The court rejected plaintiffs' claim that the agreement to arbitrate applies only to claims "relating to" the release of claims, and their substantive ADEA claims are not related to the release of claims. Rather, the court found that the agreements' "relating to" sentence showed the parties' intent to arbitrate both disputes about the release and substantive ADEA claims. Therefore, the ADEA claims were covered by the agreements. The court explained that, absent a contrary congressional command, General Mills can compel employees who signed the agreements to arbitrate their ADEA claims. In this case, the court concluded that no "contrary congressional command" overrides the Federal Arbitration Act's (FAA), 9 U.S.C. 1 et seq., mandate to enforce the parties' agreement to arbitrate substantive ADEA claims. Accordingly, the court reversed and remanded for further proceedings.
Court Description: Benton, Author, with Shepherd, Circuit Judge, and Strand, District Judge] Civil case - Employment discrimination. In a dispute over whether terminated employees knowingly and voluntarily waived their rights and claims under the Age Discrimination in Employment Act by accepting benefits and signing waivers, the district court erred in denying General Mills' motion to compel arbitration; no contrary Congressional command overrides the Federal Arbitration Act's mandate to enforce the parties' agreement to arbitrate ADEA claims.