Hawaii

Alexander v. Gardner-Denver Co. in Hawaii Law

How Alexander v. Gardner-Denver Co. applies in Hawaii: state-specific rules, key cases, and bar exam notes for Employment Discrimination.

State Approach

Hawaii law generally supports the principles established in Alexander v. Gardner-Denver Co. by recognizing an employee's right to pursue both arbitration and judicial remedies for discrimination claims. The state encourages full access to remedies for employment discrimination, reinforcing the idea that arbitration cannot preclude civil rights litigation.

State Rule
In Hawaii, an employee may pursue Title VII claims in court despite having undergone arbitration proceedings, particularly when the arbitration process does not address statutory rights or provide adequate remedies.
Significant State Cases

Kohala Agricultural & Cultural Center v. State

The court held that arbitration agreements cannot limit an employee's rights to pursue workplace discrimination claims in court.

Matsumoto v. State

This case reaffirmed that Hawaii's laws prioritize equitable remedies for employment discrimination, allowing for court intervention even after arbitration.

Hawaiian Airlines v. Norris

The court emphasized that contractual obligations to arbitrate do not override the employee's rights under discrimination statutes.

Comparison to Federal Law

Hawaii's approach aligns with the federal principle established in Alexander v. Gardner-Denver Co.; however, Hawaii adds additional layers of protection and ensures that employees have unrestricted access to both arbitration and the judicial system for discrimination claims. This is more expansive than some federal interpretations, which may view arbitration as a complete remedy.

Bar Exam Note

Understanding Hawaii's application of employee rights regarding arbitration and discrimination claims is crucial for the Hawaii bar exam, particularly in relation to employment law.

Practice Pointers
  • Always check if an arbitration agreement includes a waiver of the right to pursue discrimination claims.
  • Familiarize yourself with both state and federal laws on employment discrimination.
  • Be prepared to argue that arbitration should not prevent access to judicial remedies based on Hawaii’s legal framework.

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