Santoro v. Accenture Federal Services
United States Court of Appeals for the Fourth Circuit
748 F.3d 217 (2014)
- Written by Steven Pacht, JD
Facts
Armand Santoro (plaintiff) worked for Accenture Federal Services, LLC (Accenture) (defendant) until Accenture fired him in 2011. In August 2005, Santoro signed an employment agreement that included an arbitration clause covering all employment-related disputes between the parties. The arbitration clause did not include a carve-out for claims brought pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank). Santoro sued Accenture in federal court in Virginia, alleging that his termination violated the Age Discrimination in Employment Act, the Family and Medical Leave Act, and the Employee Retirement Income Security Act. Accenture moved to compel arbitration of these claims pursuant to the arbitration clause. Santoro responded that the arbitration clause was unenforceable because three whistleblower-related provisions of Dodd-Frank voided any arbitration clause that did not carve out Dodd-Frank claims, even if the claims at issue did not involve whistleblower claims under Dodd-Frank. The district court granted Accenture’s motion. Santoro appealed.
Rule of Law
Issue
Holding and Reasoning (Shedd, J.)
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