556 U.S. 247 (2009)
14 Penn Plaza LLC v. Pyett is a landmark Supreme Court decision at the intersection of labor law, arbitration, and employment discrimination.
Is a provision in a collective bargaining agreement that clearly and unmistakably requires union members to arbitrate ADEA claims enforceable, thereby precluding a judicial forum for those claims?
A collective bargaining agreement that clearly and unmistakably requires union members to arbitrate federal statutory discrimination claims—here, ADEA claims—is enforceable as a matter of federal law. Such a provision waives only the judicial forum and not the employees' substantive statutory rights, which remain fully applicable in arbitration. The clear-and-unmistakable standard, drawn from Wright v. Universal Maritime Service Corp., requires that the CBA expressly reference the statutory claims at issue or otherwise unmistakably commit those claims to arbitration.
Yes. The Supreme Court held that a CBA's clear and unmistakable agreement to arbitrate ADEA claims is enforceable, and employees are bound to arbitrate rather than litigate those claims in court.
Pyett is pivotal for understanding how statutory employment discrimination claims intersect with labor arbitration. It narrows the perceived sweep of Gardner-Denver and aligns unionized workplaces with the Court's broader pro-arbitration jurisprudence, so long as the CBA clearly and unmistakably covers the specific statutory claims. For practitioners and students, Pyett underscores: (1) the necessity of explicit CBA language enumerating statutory claims; (2) the distinction between waiving a forum and waiving substantive rights; and (3) the role of the duty of fair representation when unions control access to arbitration. The decision influences drafting, enforcement, and litigation strategies in unionized settings and remains a frequent touchstone in disputes over arbitrability of statutory claims under CBAs.