McAllister v. Connecticut Renaissance Inc.
To prevail on a claim that alleges discriminatory conduct, in violation of Title VII of the Civil Rights Act and the Americans With Disabilities Act, a plaintiff must allege that the defendant is an employer. The plaintiff, Darrin McAllister, sued the defendants, alleging that the defendants violated his rights under Title VII and the ADA. To prevail, the plaintiff is required to prove that the defendants engaged in discriminatory conduct in their capacities as employers. The District Court granted the motion to dismiss of one of the defendants, Greater Bridgeport Adolescent Pregnancy Program, and the plaintiff appealed. There was no evidence that the Greater Bridgeport Adolescent Pregnancy Program was McAllister's employer or that it played any role in allegedly discriminatory conduct. McAllister's employment contract with another defendant, Connecticut Renaissance Inc., included an arbitration clause, which required arbitration of discrimination claims. "As the plain language of the Arbitration Agreement provides," wrote the 2nd Circuit, "the parties agreed to resolve their disputes by arbitration, and their agreement covered the claims McAllister asserts in the Complaint." The District Court correctly granted Connecticut Renaissance's motion to compel arbitration, pursuant to the arbitration clause. The 2nd Circuit affirmed the judgment of the District Court, Eginton, J.