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Campbell v. General Dynamics Government Systems Corp.
United States Court of Appeals for the First Circuit
407 F.3d 546 (1st Cir. 2005)
Roderick Campbell (plaintiff) began working for General Dynamics Government Systems Corporation (General Dynamics) (defendant) on June 6, 2000. On April 30, 2001, General Dynamics sent an email to its employees stating that General Dynamics had adopted a new dispute-resolution policy (the policy). The email explained that the new four-step approach to dispute resolution would conclude with arbitration. The email did not include the text of the policy. Rather, the email included embedded links to two documents and urged employees to read the documents carefully. The first link opened a brochure. The second page of the brochure informed employees that, by continuing their employment after the effective date of the policy, the employees would agree to have any discrimination claims governed by the policy. A shaded box at the bottom of that page identified the policy as General Dynamics’s exclusive means of resolving workplace disputes. The second link opened a dispute-resolution handbook that included the full text of the policy. The email did not require employees to acknowledge that they had received or read the policy. General Dynamics monitored whether employees opened the email and was aware that Campbell had opened the email, but General Dynamics did not monitor whether employees clicked on the links. On December 30, 2002, General Dynamics terminated Campbell’s employment. Campbell sued General Dynamics in state court under the Americans with Disabilities Act (ADA), alleging that General Dynamics had terminated Campbell based on his disability. General Dynamics removed the case to federal court and moved to stay the proceedings and compel arbitration based on the policy. The district court found that the email did not provide sufficient notice to Campbell that continuing his employment would waive his rights to a judicial forum. The district court denied General Dynamics’ motion. General Dynamics appealed.
Rule of Law
Holding and Reasoning (Selya, J.)
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