4th Circuit: Santoro v. Accenture Federal Services, L.L.C- No Invalidation of Arbitration for Non-Whistle Blower Claims by Dodd-Frank

Summary: Santoro brought suit against Accenture, alleging violations of the Age Discrimination in Employment Act (ADEA), the Family and Medical Leave Act (FMLA), the Employee Retirement Income Security Act (ERISA), and the District of Columbia Human Rights Act. Accenture moved to compel arbitration under the employment contract with Santoro, who countered that the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 invalidated all arbitration agreements by publicly-traded companies that lack a carve-out for Dodd-Frank whistle blower claims, even if the plaintiff is not a whistle blower. The Court of Appeals rejected this as an over-extension of Dodd-Frank, which only invalidated arbitration provisions relating only to whistle blower claims “arising under” 7 U.S.C. § 26(n) and 18 U.S.C. § 1514A(e). For a copy of the opinion, please see: Santoro v. Accenture Federal Services, L.L.C- No Invalidation of Arbitration for Non-Whistle Blower Claims by Dodd-Frank