Allen v. Reliaquest, LLC, 8:23-cv-00806

Background

Aaron Allen, a former employee of ReliaQuest, LLC, sued the company for race and religious discrimination under Title VII and the Florida Civil Rights Act, as well as various contract-related claims.
Allen was terminated from ReliaQuest in March 2022 and, on the same day, was offered and signed a severance agreement waiving most legal claims against ReliaQuest.
Allen alleged that ReliaQuest management told him the agreement did not waive federal discrimination claims (e.g., Title VII claims that could be raised in the EEOC).
Despite attempts, Allen did not consult with an attorney before signing the agreement, relying on management’s assurances.
Allen subsequently filed an EEOC charge and, after receiving a right to sue letter, brought this lawsuit raising discrimination and contractual claims.
The court converted ReliaQuest’s motion to dismiss to a motion for summary judgment on the interpretation of the severance agreement’s release provision.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the release provision of the severance agreement bar Allen's individual discrimination and contract claims?	Allen: The release excludes individual claims protected by law, allowing federal discrimination lawsuits.	ReliaQuest: The release is clear, covers all individual claims except those not waivable by law (e.g. EEOC filings).	The release provision is unambiguous and bars Allen’s individual claims; exceptions do not include individual federal lawsuits.
Is the release language ambiguous as to what claims are waived or preserved?	Allen: The language about claims "and" relief is ambiguous and could be read to preserve more rights.	ReliaQuest: The language is clear; Allen waived all claims except administrative filings permitted by law.	No ambiguity; the court interprets the language in its ordinary sense and rejects Allen’s contrary readings.
Should extrinsic evidence (e.g., management’s statements) be considered to interpret the release?	Allen: Ambiguity and oral representations justify considering parol evidence.	ReliaQuest: The provision is clear—extrinsic evidence is unnecessary.	Not needed; contract's plain text is clear, so extrinsic evidence is not considered.
Has Allen preserved a challenge to the validity or voluntariness of the release?	Allen: Relied on oral assurances, did not consult counsel, so voluntariness is disputed.	ReliaQuest: Not yet fully briefed; issue not currently before the court.	Court defers ruling on knowing and voluntary nature of the release; parties may raise the issue later.

Key Cases Cited

Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (summary judgment standard and materiality of facts)
Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (movant’s burden in summary judgment and shifting burden framework)
Hibiscus Assocs. Ltd. v. Bd. of Trs. of Policemen and Firemen Retirement Sys. of the City of Detroit, 50 F.3d 908 (11th Cir. 1995) (plain language of contract governs intent)
Hurt v. Leatherby Ins. Co., 380 So. 2d 432 (Fla. 1980) (plain meaning rule in contract interpretation)
Jenkins v. Eckerd Corp., 913 So. 2d 43 (Fla. 1st DCA 2005) (courts may not consider extrinsic evidence for unambiguous contract provisions)