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Sniezek v. Kansas City Chiefs Football Club

Citations: 402 S.W.3d 580; 2013 Mo. App. LEXIS 226; 2013 WL 661632Docket: No. WD 75206

Court: Missouri Court of Appeals; February 25, 2013; Missouri; State Appellate Court

Narrative Opinion Summary

The case involves an appeal by a professional football club against a circuit court's decision denying their motion to compel arbitration of an age discrimination claim filed by a former employee. The employee, who had worked for the club for nearly 29 years before her termination, contested the validity of an arbitration agreement she signed on her first day of employment. The club argued that the agreement constituted a binding contract, citing mutual promises to arbitrate and the offer of at-will employment as consideration. The circuit court, however, ruled against the club, finding insufficient evidence of a valid arbitration agreement. The court highlighted that the arbitration agreement lacked mutual obligations, as it only imposed duties on the employee, and that at-will employment was insufficient consideration under Missouri law. The appellate court affirmed the circuit court’s decision, concluding that the club failed to demonstrate the enforceability of the arbitration agreement due to the absence of consideration. The court noted the contrast with other jurisdictions where continued employment might suffice as consideration but reiterated that Missouri law requires more substantive contractual elements for enforceable agreements.

Legal Issues Addressed

Consideration in Employment Contracts

Application: The court determined that the offer of at-will employment did not constitute sufficient consideration to enforce the arbitration agreement.

Reasoning: The Chiefs argue that their mutual promise to arbitrate and their offer of at-will employment constitute valid consideration.

Contractual Elements in Arbitration Agreements

Application: The court examined whether the arbitration agreement contained offer, acceptance, and consideration, as required under Missouri law.

Reasoning: Under Missouri law, an arbitration agreement must contain essential contract elements, specifically offer, acceptance, and consideration.

Enforceability of Arbitration Agreements

Application: The court assessed whether the signed arbitration agreement between the employee and the employer was legally binding under state contract law.

Reasoning: The Chiefs argue that an arbitration agreement signed by Sniezek on her first day of work is legally binding.

Impact of At-Will Employment on Arbitration Agreements

Application: The court ruled that at-will employment does not meet the consideration requirement for arbitration agreements under Missouri law.

Reasoning: Sniezek’s promise to arbitrate was deemed unsupported by sufficient consideration due to her at-will employment with the Chiefs, which was not a legally enforceable relationship.

Mutual Obligations in Arbitration Agreements

Application: The agreement was found lacking in mutual obligations, as it only imposed arbitration duties on the employee, not the employer.

Reasoning: The Agreement's language only reflects promises made by Sniezek, with no obligations imposed on the Chiefs.