Melena v. Anheuser-Busch

Joann Melena (plaintiff) was a nonunion employee of Anheuser-Busch, Inc. (defendant) in Mt. Vernon, Illinois. Anheuser-Busch mailed a letter to the Mt. Vernon employees stating that it would implement a dispute-resolution program and providing several program documents. The program’s policy statement provided that the dispute-resolution procedure was an agreement to arbitrate under the Federal Arbitration Act (FAA). The statement further provided that any dispute unable to be resolved through the program would be subject to arbitration by a neutral third party as a substitute for a judge or jury in a court setting. The statement explained that by continuing employment with Anheuser-Busch, an employee agreed to submit all employment-related claims against the company or individual managers to the program. Anheuser-Busch also presented the terms of the program to Mt. Vernon employees during an in-person meeting and through posters put up in the facilities. A year later, Anheuser-Busch distributed a handbook to employees that described the dispute-resolution program, and employees signed an acknowledgement stating that they received, read, and understood the handbook and that they knew that Anheuser-Busch reserved the right to modify the terms. Melena suffered a workplace-related injury and filed a workers’-compensation claim with the Illinois Industrial Commission. While she was receiving disability benefits, Melena was fired by Anheuser-Busch. Melena filed suit in state court for retaliatory discharge under the Illinois Workers’ Compensation Act. Citing the dispute-resolution-program materials, Anheuser-Busch moved to compel arbitration and either dismiss the case or stay proceedings. The trial court denied the motion, and Anheuser-Busch appealed. The appellate court affirmed the trial court’s ruling, finding that Melena did not voluntarily enter into the arbitration agreement because the agreement was made a condition of employment. Anheuser-Busch appealed to the Illinois Supreme Court.