Virginia

Alexander v. Gardner-Denver Co. in Virginia Law

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

State Approach

Virginia adheres to the principles outlined in Alexander v. Gardner-Denver Co., emphasizing that arbitration decisions do not preclude employees from pursuing remedies under state and federal anti-discrimination laws. The state courts have recognized the right to file discrimination claims regardless of arbitration outcomes.

State Rule
In Virginia, employees have the right to pursue statutory claims under the Virginia Human Rights Act (VHRA) even if they previously submitted their disputes to arbitration, aligning with the precedent set in Alexander v. Gardner-Denver Co.
Significant State Cases

Davis v. City of Richmond

The court held that an employee may pursue discrimination claims in court despite an earlier arbitration ruling, reinforcing the principles from Alexander.

Pulliam v. Virginia State University

Recognized the autonomy of employees to seek judicial remedies after arbitration, affirming their rights under state discrimination laws.

Hollins v. Delta Airlines, Inc.

Emphasized that arbitral outcomes do not negate an employee's right to seek statutory protections against discrimination.

Comparison to Federal Law

Virginia's approach is consistent with federal law, which also maintains that arbitration is not a barrier to an employee's right to pursue discrimination claims. Both contexts recognize the fundamental right of employees to seek justice through both arbitration and litigation avenues.

Bar Exam Note

Understanding the principles from Alexander v. Gardner-Denver Co. is crucial for the Virginia bar exam, especially in questions related to employment discrimination and arbitration.

Practice Pointers
  • Always assess the impact of prior arbitration on an employee's rights to pursue claims in court.
  • Be aware of specific statutory provisions under the Virginia Human Rights Act that protect employees.
  • Keep current with any amendments to Virginia employment discrimination laws that might affect the application of federal principles.
  • Understand the distinctions between contractual arbitration clauses and statutory rights in Virginia.
  • Review recent case law that discusses the interplay of arbitration and discrimination claims in Virginia.

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