Summary
This D.C. Circuit opinion addresses whether a settlement agreement resolving a union grievance under a collective bargaining agreement bars an employee’s subsequent Title VII discrimination lawsuit. The court held that the agreement’s plain language only resolved contractual grievance claims between the union and the employer, and did not unambiguously waive the employee’s independent statutory rights under Title VII. Consequently, the court vacated the district court’s grant of summary judgment in favor of the employer and remanded the case for further proceedings.
Topics
Practice areas
Questions Presented
- Whether the settlement agreement in the union grievance process bars the employee’s Title VII discrimination claim.
Holdings
- The settlement agreement resolved only the union grievance claims under the collective bargaining agreement and did not affect the employee’s Title VII action; therefore the district court’s grant of summary judgment was improper.
Key quotations
“The agreement’s plain language is addressed specifically to settlement of the union’s grievance claims for breach of the CBA, and it does not purport to treat with Jones’s then‑pending lawsuit alleging a violation of Title VII.” (at *5)
“A grievance is designed to vindicate a contractual right under a CBA, while a lawsuit under Title VII asserts independent statutory rights accorded by Congress.” (at *5)
Factual background
Catherine Jones, a WMATA employee and union member, filed Title VII and 42 U.S.C. §1981 claims alleging race discrimination, hostile work environment, and retaliation. The union brought two grievance charges on her behalf, which were settled by a one‑page agreement that resolved only the grievance claims. Jones did not sign the settlement. The district court treated the settlement as an unconditional release of all related claims and granted summary judgment.
Procedural history
The district court granted summary judgment to WMATA, holding that the union‑grievance settlement barred the Title VII claims. The D.C. Circuit reviewed de novo and vacated that judgment.
Remand instructions
Remand for further proceedings consistent with the holding that the settlement does not bar the Title VII claims.