Warfield v. Beth Israel Deaconess Medical Center, Inc.
Massachusetts Supreme Judicial Court
910 N.E.2d 317, 454 Mass. 390 (2009)

- Written by Whitney Waldenberg, JD
Facts
Carol Warfield (plaintiff) entered into an employment agreement with Beth Israel Deaconess Medical Center, Inc. (BIDMC) (defendant) to serve as the hospital’s chief anesthesiologist. Warfield’s employment contract contained an arbitration clause. Shortly after she assumed the role of chief anesthesiologist, BIDMC hired a new chief of surgery, Josef Fischer (defendant), and a new CEO, Paul Levy (defendant). Warfield alleged that she was subjected to gender-based discrimination by Fischer, and when Warfield reported the discrimination to Levy, Levy failed to address it. Levy eventually terminated Warfield’s appointment as chief anesthesiologist. Warfield filed suit against BIDMC, Fischer, and Levy, asserting statutory claims of gender discrimination and retaliation, as well as common-law claims for tortious interference with contract and defamation. BIDMC, Fischer, and Levy moved to dismiss the action and compel arbitration based on the arbitration clause in Warfield’s employment contract, which stated that “[a]ny claim or controversy or dispute arising out of or in connection with this Agreement or its negotiations shall be settled by arbitration.” The lower court denied the motion to dismiss, and BIDMC, Fischer, and Levy appealed.
Rule of Law
Issue
Holding and Reasoning (Botsford, J.)
Dissent (Cowin, J.)
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