Katherine Anderson v. Jeffrey Hansen, No. 21-2719 (8th Cir. 2022)
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Plaintiffs, independent contractors of American Family Life Insurance Company of Columbus (Aflac), alleged that an Aflac employee, sexually assaulted Plaintiff in her hotel room during a work conference in St. Louis, Missouri. Plaintiffs filed suit against Defendant, asserting tort claims for battery, assault, false imprisonment, and loss of consortium, among others. the beneficiary under Plaintiffs’ Arbitration Agreements with Aflac. The district court denied the motion as to the aforementioned claims, holding that they did not arise under or relate in any way to the arbitration agreements. Defendant appealed, arguing that the claims fall within the scope of the arbitration agreements.
The Eighth Circuit affirmed. The court held that Plaintiffs’ tort claims do not fall within the scope of the Arbitration Agreements. The facts underlying Plaintiffs’ tort claims do not touch matters covered by Plaintiffs’ Arbitration Agreements in light of the Agreements’ limiting language requiring the “dispute arise under or relate in any way to the Associate’s Agreements. As a result, the district court did not err in denying Defendant’s motion to compel arbitration.
Court Description: [Smith, Author, with Wollman and Grasz, Circuit Judges] Civil case - Arbitration. Plaintiffs, independent contractors of Aflac alleged defendant, an Aflac employee, sexually assaulted plaintiff Katherine at a work conference, and they sued him for battery, assault, false imprisonment and loss of consortium; defendant moved to compel arbitration of the claims, arguing he was a third-party beneficiary of the plaintiffs' Arbitration Agreements with Aflac; the district court did not err in rejecting the motion to compel arbitration as the claims did not arise under or fall within the scope of the arbitration agreements. Judge Grasz, dissenting.
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