THIRD CIRCUIT COURT OF APPEALS HOLDS THAT EMPLOYEE'S STATE-LAW CLAIMS AGAINST EMPLOYER WERE ARBITRABLE AND SUPERVISOR WAS NOT A NECESSARY PARTY IN AM. GEN. LIFE AND ACCIDENT INS. CO. V. WOOD - Journal of American Arbitration (JAA) - Vol. 6, No. 2
Larry Wood was employed by American General Life and Accident Insurance Company (“AGLA”) from 1997 to 2000. Am. Gen. Life & Accident Ins. Co. v. Wood, 429 F.3d 83, 85 (3d Cir. 2005). Nearly one year after Wood began his employment with AGLA, the company implemented an Employee Dispute Resolution Program (“Program”). Id. Employees attended a presentation about the Program, received informational packets, and signed an agreement stating that they understood they were required “to adhere to the Employee Dispute Resolution Plan and its requirement for submission of employment disputes to mediation and/or binding arbitration.” Id. at 85-86 (quoting Joint Appendix at 56 (“J.A.”) filed by the parties in this proceeding). Wood asserted that he was forced to sign the agreement without an opportunity to read it and that the general manager of AGLA told the employees that the Program “would not in any way prevent an employee of AGLA from suing the company and that the program did not take any rights away from the employees.” Id. at 85 (quoting J.A. at 57). Moreover, Wood claimed that he was never told that by signing the agreement he would be giving up his right to sue AGLA for any discrimination. Id. at 86.