## Facts

- Charity Emeronye, a Black Nigerian woman, worked for CACI International, Inc. first as a temporary coder and later as a permanent paralegal.
- On August 6, 1997, CACI offered Emeronye a permanent paralegal position; the offer letter directed her to sign and return an attached two-page “Employee Agreement.”
- The offer letter stated that signing the Employee Agreement acknowledged Emeronye’s understanding of its requirements and agreement to abide by them.
- Emeronye signed the Employee Agreement, which required employment-related disputes to proceed to mediation and, if unresolved, binding arbitration, including statutory discrimination claims.
- Emeronye later alleged discrimination and retaliation, including denial of promotions based on race and/or national origin, and retaliation after internal complaints.
- In August 1999, Emeronye filed an internal EEO complaint with CACI.
- In September 2000, Emeronye sued under Title VII and 42 U.S.C. § 1981; CACI moved to dismiss and compel arbitration under the agreement.

## Issues

1. Whether the Federal Arbitration Act applies to the parties’ employment agreement, or whether the FAA’s § 1 exemption excludes the agreement.
2. Whether Emeronye assented to the arbitration provision, or whether the agreement is unenforceable as adhesive or lacking knowing consent.
3. Whether the arbitration clause validly and clearly encompasses Title VII and § 1981 discrimination and retaliation claims.
4. If all claims are arbitrable, whether the court may dismiss the action rather than stay it pending arbitration.

## Decision

- The court granted CACI’s motion to dismiss and compel arbitration.
- The FAA applied because the § 1 exemption is narrowly limited to certain transportation workers, not ordinary employment agreements.
- Emeronye was bound by the signed agreement; her claimed failure to recall reading it and the absence of special emphasis on arbitration did not negate assent.
- The arbitration clause covered statutory discrimination and retaliation claims and did not waive substantive rights; it selected an arbitral forum.
- Because all claims fell within the arbitration provision, dismissal (rather than a stay) was permitted.

## Legal Principles

- The FAA generally governs arbitration clauses in ordinary employment agreements; the § 1 exemption is limited and does not broadly exclude employment contracts.
- A party who signs an employment agreement is ordinarily bound by its terms absent a showing such as fraud, duress, or unconscionability; lack of recollection of reading the document is insufficient.
- Agreements that expressly require arbitration of employment-related disputes, including Title VII and § 1981 claims, are enforceable; arbitration changes the forum for enforcement but not the substantive statutory rights.
- When all claims in a suit are subject to arbitration, a court may compel arbitration and dismiss the case.

## Conclusion

The court enforced the employee’s signed ADR agreement, held the FAA applicable to the employment contract, compelled mediation and binding arbitration of the Title VII and § 1981 claims, and dismissed the federal lawsuit because no claims remained for judicial resolution.


Emeronye v. CACI Int'l, Inc., 141 F. Supp. 2d 82 (D.D.C. 2001)