EEOC v. Waffle House, Inc. - 534 U.S. 279, 122 S. Ct. 754 (2002)

Rule:

Pursuant to Title VII of the Civil Rights Act of 1964, 42 U.S.C.S. § 2000e et seq., and the Americans with Disabilities Act, 42 U.S.C.S. § 12101 et seq., whenever the Equal Employment Opportunity Commission chooses from among the many charges filed each year to bring an enforcement action in a particular case, the agency is seeking to vindicate a public interest, not simply provide make-whole relief for the employee, even when it pursues entirely victim-specific relief.

Facts:

Respondent's employees must each sign an agreement requiring employment disputes to be settled by binding arbitration. After Eric Baker suffered a seizure and was fired by respondent, he filed a timely discrimination charge with the Equal Employment Opportunity Commission (EEOC) alleging that his discharge violated Title I of the Americans with Disabilities Act of 1990 (ADA). The EEOC subsequently filed the present enforcement suit, to which Baker was not a party, alleging that respondent’s employment practices, including Baker’s discharge “because of his disability,” violated the ADA and that the violation was intentional and done with malice or reckless indifference. The complaint requested injunctive relief to eradicate the effects of respondent’s past and present unlawful employment practices; specific relief designed to make Baker whole, including backpay, reinstatement, and compensatory damages; and punitive damages for malicious and reckless conduct. Respondent petitioned under the Federal Arbitration Act (FAA) to stay the EEOC's suit and compel arbitration, or to dismiss the action, but the District Court denied relief. The Fourth Circuit concluded that the arbitration agreement between Baker and respondent did not foreclose the enforcement action because the EEOC was not a party to the contract, but had independent statutory authority to bring suit in any federal district court where venue was proper. Nevertheless, the court held that the EEOC was limited to injunctive relief and precluded from seeking victim-specific relief because the FAA policy favoring enforcement of private arbitration agreements outweighs the EEOC's right to proceed in federal court when it seeks primarily to vindicate private, rather than public, interests. Certiorari was granted. 

Issue:

Did the agreement between the employer and the employee to arbitrate employment-related disputes bar the EEOC from pursuing victim-specific judicial relief in an ADA enforcement action?  

Answer:

No.

Conclusion:

The judgment was reversed and the case was remanded for further proceedings. Pursuant to Title VII of the Civil Rights Act of 1964, 42 U.S.C.S. § 2000e et seq., and the ADA, whenever the EEOC chose to bring an enforcement action in a particular case, it was seeking to vindicate a public interest, not simply providing make-whole relief for the employee, even when it pursued entirely victim-specific relief. Thus, the fact that the employee had signed a mandatory arbitration agreement did not limit the remedies available to the EEOC because the text of the applicable statutes did not authorize courts to balance the competing policies of the ADA and the FAA or to second-guess the EEOC's judgment concerning which of the remedies authorized by law that it was to seek in any given case. The ADA and Title VII specifically granted the EEOC exclusive authority over the choice of forum and the prayer for relief once a charge had been filed.