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What is the Significance of the Pyatt Decision in Labor Law?

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    District Court Decision

    • The watchmen sued Pyatt for age discrimination in a separate lawsuit and were awarded a settlement by district court. Pyatt appealed the legality of the lawsuit; appeals courts denied Pyatt's claim based on the 1974 Alexander v. Gardner-Denver decision, which ruled that private civil rights-related litigation may be pursued in addition to related arbitration claims under a collective bargaining agreement. Pyatt reacted by appealing to the United States Supreme Court.

    Supreme Court Decision

    • The Supreme Court reversed the lower courts' decision by a vote of 5 to 4. They reasoned that the private lawsuit represented a case of double jeopardy since the union's collective bargaining agreement allowed the union to seek damages for the workers through arbitration. They determined that the Gardner-Denver decision is only valid for cases in which the collective bargaining agreement does not contain a specific clause for civil rights arbitration.

    Significance

    • The Penn Plaza vs. Pyatt decision is a blow to the right of employees to pursue private litigation for civil right related infringement. If a union collective bargaining agreement specifies terms of arbitration for civil rights claims, a private lawsuit may not be pursued.

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