Arbitration Clause Can't Bar Punitive Damages, Appeals Court Says
"We are persuaded that the arbitration agreement's bar on punitive damages claims is unenforceable because it violates the public policy of the LAD," the Appellate Division said.
August 23, 2018 at 05:58 PM
3 minute read
A New Jersey appeals court has upheld a contract requiring a woman alleging sexual harassment and hostile working conditions to arbitrate her claims, but said she must be allowed to pursue punitive damages in those proceedings.
The Appellate Division panel said Aug. 23 in Roman v. Bergen Logistics that plaintiff Milagros Roman knowingly assented to the arbitration requirement in September 2015, when she was hired by Bergen Logistics of North Bergen.
But, the court said, “An agreement barring the recovery of punitive damages to victims of employment discrimination under the [Law Against Discrimination] allows an employer's upper management to be willfully indifferent to the most egregious forms of discriminatory conduct without fear of punishment and without the incentive to stop or prevent the discriminatory conduct that the availability of punitive is intended to provide.”
According to the decision, Roman, a human resources generalist, was fired in December 2015 after repeatedly claiming that she had been subjected to sexual harassment by her supervisor, Gregg Oliver, the director of human resources, and that she was forced to work in a hostile work environment.
She filed a lawsuit in Bergen County Superior Court. A judge, however, dismissed her lawsuit on summary judgment, saying she was bound by the arbitration agreement she signed when she began working at Bergen Logistics.
The arbitration agreement contained a clause that barred plaintiffs from seeking punitive damages under the Law Against Discrimination.
That clause was unenforceable because it ran against the public policy, said Appellate Division Judges Allison Accurso, Amy O'Connor and Francis Vernoia in the unpublished decision.
“We are persuaded that the arbitration agreement's bar on punitive damages claims is unenforceable because it violates the public policy of the LAD,” the judges said in the per curiam ruling.
The panel noted that the Legislature amended the LAD in 1990 to ensure that punitive damages are available to anyone who asserts a claim under the statute.
“The availability of punitive damages saves the LAD's public policy of eradicating employment discrimination by focusing on the deterrence and punishment of particularly serious conduct by certain employees,” the court said.
“In our view, a contract provision barring an employee's access to punitive damages under the LAD not only violates public policy by eliminating a remedy the Legislature expressly declared is available to all victims of discrimination … it also eviscerates an essential element of the LAD's purpose—deterrence and punishment of the most egregious discriminatory conduct by employees who, by virtue of their position and responsibilities … control employer policies and actions that should prevent discriminatory conduct in the workplace,” the panel said.
Roman is represented by Peter Valenzano of Mashel Law in Morgantown.
“We are pleased the court endorsed our view that punitive damages are available and that clauses barring punitive damages claims are unenforceable,” he said, adding that he and his client are prepared for arbitration.
Bergen Logistics was represented by Jessica Sussman of the Morristown office of Jackson Lewis. Oliver was represented by Kyle Wu of the Philadelphia office of Margolis Edelstein. Neither returned a call seeking comment.
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2024 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View AllHit by Mail Truck: Man Agrees to $1.85M Settlement for Spinal Injuries
Appellate Div. Follows Fed Reasoning on Recusal for Legislator-Turned-Judge
4 minute readChiesa Shahinian Bolsters Corporate Practice With 5 From Newark Boutique
5 minute readOn the Move and After Hours: Brach Eichler; Cooper Levenson; Marshall Dennehey; Archer; Sills Cummis
7 minute readTrending Stories
Who Got The Work
Michael G. Bongiorno, Andrew Scott Dulberg and Elizabeth E. Driscoll from Wilmer Cutler Pickering Hale and Dorr have stepped in to represent Symbotic Inc., an A.I.-enabled technology platform that focuses on increasing supply chain efficiency, and other defendants in a pending shareholder derivative lawsuit. The case, filed Oct. 2 in Massachusetts District Court by the Brown Law Firm on behalf of Stephen Austen, accuses certain officers and directors of misleading investors in regard to Symbotic's potential for margin growth by failing to disclose that the company was not equipped to timely deploy its systems or manage expenses through project delays. The case, assigned to U.S. District Judge Nathaniel M. Gorton, is 1:24-cv-12522, Austen v. Cohen et al.
Who Got The Work
Edmund Polubinski and Marie Killmond of Davis Polk & Wardwell have entered appearances for data platform software development company MongoDB and other defendants in a pending shareholder derivative lawsuit. The action, filed Oct. 7 in New York Southern District Court by the Brown Law Firm, accuses the company's directors and/or officers of falsely expressing confidence in the company’s restructuring of its sales incentive plan and downplaying the severity of decreases in its upfront commitments. The case is 1:24-cv-07594, Roy v. Ittycheria et al.
Who Got The Work
Amy O. Bruchs and Kurt F. Ellison of Michael Best & Friedrich have entered appearances for Epic Systems Corp. in a pending employment discrimination lawsuit. The suit was filed Sept. 7 in Wisconsin Western District Court by Levine Eisberner LLC and Siri & Glimstad on behalf of a project manager who claims that he was wrongfully terminated after applying for a religious exemption to the defendant's COVID-19 vaccine mandate. The case, assigned to U.S. Magistrate Judge Anita Marie Boor, is 3:24-cv-00630, Secker, Nathan v. Epic Systems Corporation.
Who Got The Work
David X. Sullivan, Thomas J. Finn and Gregory A. Hall from McCarter & English have entered appearances for Sunrun Installation Services in a pending civil rights lawsuit. The complaint was filed Sept. 4 in Connecticut District Court by attorney Robert M. Berke on behalf of former employee George Edward Steins, who was arrested and charged with employing an unregistered home improvement salesperson. The complaint alleges that had Sunrun informed the Connecticut Department of Consumer Protection that the plaintiff's employment had ended in 2017 and that he no longer held Sunrun's home improvement contractor license, he would not have been hit with charges, which were dismissed in May 2024. The case, assigned to U.S. District Judge Jeffrey A. Meyer, is 3:24-cv-01423, Steins v. Sunrun, Inc. et al.
Who Got The Work
Greenberg Traurig shareholder Joshua L. Raskin has entered an appearance for boohoo.com UK Ltd. in a pending patent infringement lawsuit. The suit, filed Sept. 3 in Texas Eastern District Court by Rozier Hardt McDonough on behalf of Alto Dynamics, asserts five patents related to an online shopping platform. The case, assigned to U.S. District Judge Rodney Gilstrap, is 2:24-cv-00719, Alto Dynamics, LLC v. boohoo.com UK Limited.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250