Williams v. Phillips Petroleum Co.
United States Court of Appeals for the Fifth Circuit
23 F.3d 930 (1994)
Williams and five coworkers (Houston workers) (plaintiffs) worked for Phillips Petroleum Company (Phillips) (defendant) in Houston, Texas. In 1992, Phillips laid off 27 employees across several locations in Houston without providing notice. Phillips also laid off over 500 employees at its Bartlesville, Oklahoma, plant. Phillips had provided the Bartlesville employees 60 days’ notice as required by the Workers Adjustment and Retraining Notification Act (WARN). All laid-off employees executed claims releases in exchange for enhanced layoff benefits. Phillips allowed up to 45 days for employees to review the releases, and the releases encouraged the employees to discuss their rights with attorneys. The releases were written in plain English. The Houston locations and the Bartlesville plant did not share staff or equipment and were not otherwise linked. The six Houston workers brought an action against Phillips for failing to provide 60 days’ notice in violation of WARN and sought to void their claims releases. The Houston workers did not return the compensation from the enhanced layoff benefits when they filed suit. The district court granted summary judgment in favor of Phillips.
Rule of Law
Holding and Reasoning (Smith, J.)
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