Legal Memorandum: Analysis of "Lloyd v. HOVENSA, LLC"

Issue: What were some significant points in the Third Circuit’s employment discrimination case, Lloyd v. HOVENSA, LLC?

Area of Law: Employee Law
Keywords: Employment discrimination case; Lloyd v. HOVENSA, LLC
Jurisdiction: Federal
Cited Cases: 369 F.3d 263
Cited Statutes: 24 V.I.C. § 74a
Date: 11/01/2004

The case of Lloyd v. HOVENSA, LLC, and Wyatt V.I., Inc., 369 F.3d 263 (3d Cir. 2004), involved a statutory claim of employment discrimination against HOVENSA and Wyatt.  In Lloyd, the plaintiff disputed the validity of a pre-employment dispute resolution agreement that he signed prior to Wyatt considering his application for employment.  His claim was for discrimination in Wyatt’s failing to hire him.  Id. at 266-67.  The dispute resolution agreement was written in the first person with the employment applicant stating his or her agreement to resolve disputes by arbitration.  Id. at 266.  Its sole purpose was to address resolution of disputes during Wyatt’s application and hiring process.  Id. 

Additionally, Lloyd’s claim arose out of Wyatt’s alleged conduct during the application process, not during the course of employment.  Lloyd filed a discrimination suit asserting, among other claims, that Wyatt had discriminated against him on the basis of race.  See id. at 266-67.  Under the terms of Lloyd’s dispute resolution agreement, a discrimination claim based on a failure to hire fell within the scope of issues to be arbitrated. 

In Lloyd, the plaintiff challenged the enforceability of the agreement because, he alleged, various AAA rules incorporated in the agreement were unconscionable and Wyatt’s use of the dispute resolution agreement demonstrated a pattern of discrimination against applicants based on race.  Wyatt challenged whether the district court’s dismissal of the plaintiff’s complaint rather than staying the matter pending arbitration was proper.  Although the Third Circuit […]

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