Massachusetts
How Alexander v. Gardner-Denver Co. applies in Massachusetts: state-specific rules, key cases, and bar exam notes for Employment Discrimination.
In Massachusetts, the principles established in Alexander v. Gardner-Denver Co. are embraced within the context of employment discrimination law, emphasizing that employees may pursue claims under both state law and collective bargaining agreements without being limited by arbitration decisions. The Massachusetts courts recognize that an employee's right to access judicial remedies remains intact regardless of parallel arbitration processes.
In Massachusetts, employees can pursue statutory discrimination claims under Massachusetts General Laws Chapter 151B, even if they have previously participated in arbitration concerning the same employment issue, as arbitration does not preclude judicial review when statutory rights are involved.
The Massachusetts Superior Court held that an employee's right to bring a claim under Chapter 151B is not waived by submitting to arbitration under a collective bargaining agreement.
The court reaffirmed that arbitration decisions do not impact the individual's ability to file a lawsuit for discrimination under state law.
The court ruled that arbitration did not preclude a claimant from seeking judicial remedies for perceived discriminatory treatment.
Massachusetts's approach is cognizant of the principles from Alexander v. Gardner-Denver Co. but is notably more liberal, allowing for dual-track litigation for discrimination claims. Unlike some federal jurisdictions that may limit claims based on earlier arbitration outcomes, Massachusetts courts permit broader access to judicial review.
Understanding the implications of Alexander v. Gardner-Denver Co. is essential for the Massachusetts bar exam, particularly within the context of employment law and arbitration issues. Candidates should be prepared to analyze cases relating to employee rights under Chapter 151B.