## Facts

- Waffle House required employees to sign an agreement requiring binding arbitration of “employment disputes.”
- Eric Baker, an employee subject to that arbitration agreement, suffered a seizure at work and was terminated.
- Baker filed a timely charge with the Equal Employment Opportunity Commission (EEOC) alleging disability discrimination under Title I of the Americans with Disabilities Act (ADA).
- The EEOC filed a federal enforcement action (with Baker not named as a party), alleging Waffle House terminated Baker because of disability and acted with malice or reckless indifference.
- The EEOC sought injunctive relief and victim-specific relief for Baker, including backpay, reinstatement, compensatory damages, and punitive damages.
- Waffle House moved under the Federal Arbitration Act (FAA) to stay or dismiss the EEOC suit and to compel arbitration based on Baker’s agreement.

## Issues

1. Whether an employee’s arbitration agreement bars or limits the EEOC from pursuing victim-specific judicial relief (backpay, reinstatement, compensatory and punitive damages) in its ADA enforcement action.

## Decision

- The Supreme Court reversed the Fourth Circuit’s limitation of the EEOC to injunctive relief.
- The Court held that an arbitration agreement between an employer and an employee does not bar the EEOC from seeking victim-specific judicial relief in an ADA enforcement action.
- The Court concluded the EEOC could proceed in federal court and seek both injunctive and monetary relief notwithstanding the employee’s agreement to arbitrate.

## Legal Principles

- The ADA incorporates Title VII’s enforcement scheme, authorizing the EEOC to sue and seek injunctions and make-whole relief, including backpay, reinstatement, and compensatory and punitive damages where permitted.
- The EEOC’s authority to litigate and select remedies is independent of the employee’s private litigation choices and contractual commitments.
- Because the EEOC is not a party to an employee’s arbitration agreement, it is not bound by that agreement and cannot be compelled to arbitrate under the FAA.
- The FAA’s pro-arbitration policy applies to parties who agreed to arbitrate and does not curtail Congress’s grant of enforcement authority to a federal agency.
- An employee’s separate arbitration or settlement may affect the relief ultimately awarded (including avoiding double recovery), but it does not eliminate the EEOC’s power to seek victim-specific relief in court.

## Conclusion

The Court held that an employee’s mandatory arbitration agreement does not restrict the EEOC’s statutory power to bring an ADA enforcement suit in federal court and to seek victim-specific remedies on behalf of the aggrieved employee, in addition to injunctive relief.


Equal Emp. Opportunity Comm’n v. Waffle House, Inc., 534 U.S. 279 (2002)