Missouri

Alexander v. Gardner-Denver Co. in Missouri Law

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

State Approach

Missouri law aligns with the principles established in Alexander v. Gardner-Denver Co. by recognizing that arbitration clauses in employment contracts do not preclude employees from pursuing statutory claims of discrimination in court. This approach emphasizes the importance of preserving an employee's right to seek judicial remedies for discrimination claims.

State Rule
In Missouri, employees can pursue legal actions for employment discrimination notwithstanding any arbitration agreement, as long as the claims involve statutory rights protected by anti-discrimination laws.
Significant State Cases

Buchanan v. American Airlines, Inc.

The court held that an employee's right to pursue statutory discrimination claims was not negated by an arbitration agreement.

Gorham v. City of Kansas City

This case confirmed that an arbitration clause cannot limit an employee's statutory rights under the Missouri Human Rights Act.

Shields v. Mo. Department of Social Services

The court ruled that public policy necessitates that arbitration agreements cannot infringe upon an individual's right to pursue discrimination claims.

Comparison to Federal Law

Missouri's approach is aligned with federal law, which also emphasizes that arbitration agreements cannot waive an employee's right to access judicial remedies for discrimination claims under Title VII or other statutes. However, some Missouri courts have placed a stronger emphasis on state-specific anti-discrimination provisions, potentially offering broader protections than the federal framework.

Bar Exam Note

Understanding the impact of Alexander v. Gardner-Denver Co. is crucial for the Missouri bar exam, particularly regarding employment discrimination and arbitration agreements.

Practice Pointers
  • Always assess whether an arbitration agreement exists in employment cases involving discrimination claims.
  • Critically analyze whether the arbitration agreement addresses statutory rights and its implications on the employee's scope for pursuing legal remedies.
  • Stay updated on recent Missouri case law that may influence interpretations of arbitration agreements and statutory employment rights.

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