Employee Rights Supreme Court
Saint Clair Adams had been hired as a sales counselor by Circuit CityStores, Inc., in California. As a condition of employment, he was requiredto sign an agreement that any disputes that arose between Adams and hisemployer would be settled by arbitration. Despite that, Adams sued CircuitCity Stores, Inc., in state court for various discrimination complaints. The Ninth Court of Appeals in California held that "Title VIIdisputes cannot be made subject to compulsory arbitration agreements" asthey do not constitute 'interstate commerce' as specified in the FederalArbitration Act (FAA). (King, 2001, Jones Day Web site) The facts in the case, as it began, are simple: Adams signed anemployment contract that demanded arbitration rather than lawsuits tosettle issues between employer and employee. When such an issue arose,however, Adams decided to pursue it in court rather than seek arbitration.Circuit City Stores, Inc., acted to compel Adams to enter into arbitration. The Ninth Circuit Court, contrary to the majority of other Circuit Courts,held that the FAA was written in such a way as to exclude all employmentagreements from the reach of the demands of the FAA. The Supreme Court
" Justice Stevens held that thephrase followed some other extremely specific terms-seamen and railroademployees-and thus should be construed to mean other similar employees. " A great part of the deliberations of the justicesrevolved around whether there was a difference in the phrase "engaged in"as opposed to a phrase not used in the FAA, "involved in. In this case, the Court's interpretationseems not only correct, but also unavoidable. ersed the Ninth Circuit Court's decision, saying that in fact the onlyagreements not subject to arbitration under FAA pertained to seamen andother transportation workers. Rather,the entire argument concerned the legal reading of a few phrases, inparticular the meaning in the FAA of "contracts of employment of seamen,railroad employees, or another class of workers engaged in foreign orinterstate commerce. The law was written in 1925, and, although there were airplanes deliveringmail and even a few people, there certainly was not an airline worker'sunion. , rather than enter into arbitration regarding his claims. What mattered at that point was the correct reading or interpretation oflanguage contained in the Federal Arbitration Act, and it came down toparsing the connotations of just a very few words. , wanted the Court to reverse the Ninth Circuit Court so that it couldsettle the dispute through arbitration. Heargued for the majority that this would destabilize the laws, because theywould be subject at that point to fashions not only in law but also inusage of the language. In short, the original law had not been in favor of or againstany particular group of workers and compelling them to arbitrate disputes;rather it had been in favor of maintaining the free flow of goods withinthe United States as a public good. Prior decisions of the Court had interpreted portions of the FAApreviously, and Adams' attorneys cited them. Justice O'Connor accused the Court majority of abandoning 'allpretense of ascertaining congressional intent with respect to the FederalArbitration Act, building instead, case by case, an edifice of its owncreation'," despite holding with the majority in the Circuit City Stores,Inc. If one were to argue that there would be some middle ground,something between confining the exception to seamen and rail transportworkers, then where, exactly, would that point be' It is far more sensibleto construct an analogy and assume that the framers of the law meant toinclude, in the imprecise language, any workers who are very like thosespecifically included. If anything, he made the point that Congress wasdemonstrating concern with the necessary free flow of goods and was actingto ensure that, rather than acting on behalf of any group of workers inparticular.
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