In Long v. Corning Incorporated, 20-1370-cv (2d Cir. May 10, 2021) (Summary Order), the Second Circuit affirmed the dismissal of plaintiff’s employment discrimination claims asserted under Title VII of the Civil Rights Act of 1964, on the ground that such claims were covered by a release.
From the Order:
On appeal Long principally argues that he did not waive his claims because he signed the separation agreement under duress and coercion.
The enforceability of the release as to Long’s Title VII claim is governed by federal law. Under Title VII, an employee may validly waive a discrimination claim so long as the waiver is made knowingly and voluntarily. Under New York law, the enforceability of the release as to Long’s [New York State Human Rights Law] claim is governed by contract law principles. If the language of a release is clear and unambiguous, the signing of a release is a jural act binding on the parties.
Here, we conclude that the District Court properly determined that Long’s claims were barred by the release in the separation agreement he signed with Corning and granted the motion to dismiss. Nor did the District Court err in denying Long leave to amend his complaint, in light of the release of claims to which Long agreed in the separation agreement with Corning.
[Footnotes and internal quotation marks omitted.]
The Court therefore “affirm[ed] for substantially the same reasons given by the District Court in its opinion and order dated March 26, 2020.”