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Third Circuit Court of Appeals held that an employee's intentional tort claim falls within the scope of an arbitration agreement according to its plain meaning.
In Steigerwalt v. Terminix Int'l Co., No. 06-4751, 2007 WL 1780054 (3d Cir. June 21, 2007), Steigerwalt signed an arbitration agreement with his employer, Terminix, a pest control organization. Steigherwalt sued Terminix after he suffered medical injuries from inhaling methyl bromide, a toxic chemical used for fumigation.
Terminix moved to stay litigation and compel arbitration. The district court dismissed non-intentional conduct claims that were barred by the Worker's Compensation law, but denied Terminix's motion to compel arbitration. The district court reasoned that the remaining alleged intentional tort claims fell outside the scope of the agreement.
On appeal, the Court reversed the district court's decision because it disagreed with the interpretive methodology the trial court employed to interpret the agreement. The plain meaning rule always comes first among interpretation principles. If the agreement's plain meaning cannot be determined, then other interpretive principles are used.
In applying this principle, the Court noted that the particular agreement applies to "all claims," according to its plain language. Illustrations of claims provided in the agreement are demonstrative, not exhaustive as the agreement says such examples are "by no means limited."
Additionally, the agreement specifically lists "torts" as an example claim. Steigerwalt's intentional tort claim is a subcategory of torts, and therefore, the claim falls neatly within the scope of the agreement.
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