Ursula Scott v. Blue Mantis, Inc.

Summary

The United States District Court for the District of Maine grants Blue Mantis, Inc.’s motion to strike Ursula Scott’s jury demand. The court holds that the contractual jury waiver was not waived by the defendant’s failure to plead it in its answer or by the timing of the motion, and that the waiver was knowingly and voluntarily entered and broadly covered Scott’s employment-related claims.

Holdings

1. A contractual jury-trial waiver is not a traditional affirmative defense that must be pleaded under Federal Rule of Civil Procedure 8(c); Rule 39 governs a motion to strike a jury demand. Blue Mantis therefore did not waive the contractual provision by omitting it from its answer.
2. Blue Mantis did not waive the contractual jury-trial waiver by moving to strike approximately three months after answering and before trial.
3. Federal law governs the enforceability of a contractual jury-trial waiver because the jury right derives from the Seventh Amendment.
4. Scott knowingly and voluntarily entered into the contractual jury-trial waiver.
5. The contractual jury waiver's broad and unambiguous language covered Scott's civil-rights claims because those claims arose from or were connected with the parties' employment relationship.

Questions Presented

1. Whether Blue Mantis waived its contractual jury-trial waiver by failing to raise it in its answer.
2. Whether Blue Mantis waived the contractual jury-trial waiver by waiting approximately three months after answering to move to strike the jury demand.
3. Whether federal or Maine law governs the enforceability of a contractual jury-trial waiver.
4. Whether Scott knowingly and voluntarily entered into the contractual jury-trial waiver.
5. Whether the plain language of the waiver unambiguously covered Scott's civil-rights claims arising from her employment.

Disposition

other