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

Aaron Allen, a Native American and African-American male, was employed by ReliaQuest from November 2021 until his termination in March 2022.
On termination day, Allen was presented a severance agreement that included a broad release of claims against ReliaQuest, with exceptions for claims to certain federal agencies like the EEOC.
Allen alleges that ReliaQuest's Senior Vice President told him the agreement did not waive claims protected by law, such as Title VII claims, and that he could sue after signing.
Allen signed the agreement after unsuccessful attempts to consult with counsel; he received severance and extended healthcare benefits.
After signing, Allen filed discrimination and contract-related claims in federal court, arguing his release was not knowing and voluntary due to misleading statements.
ReliaQuest moved for summary judgment, asserting the agreement was enforceable and barred all Allen’s claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Allen knowingly and voluntarily signed the severance agreement	He relied on Noonan’s statement and did not fully understand he was waiving all claims	Allen had adequate time, experience, and clarity to agree	Agreement was knowing and voluntary; release enforced
Whether parol evidence could clarify or modify release terms	Noonan's statements show ambiguity or fraud	Agreement is unambiguous, bars outside evidence	Parol evidence barred for unambiguous contract
Whether contract claims (fraud/mistake) survive given the release	Noonan misrepresented enforceable scope of release	Plaintiff could not justifiably rely on oral statements contradicting contract	Contract claims fail—no justifiable reliance or mutual mistake
Whether summary judgment was premature	More discovery was needed to resolve disputed facts	All material facts are undisputed; case ripe for judgment	Summary judgment not premature

Bledsoe v. Palm Beach Cnty. Soil & Water Conservation Dist., 133 F.3d 816 (11th Cir. 1998) (Title VII claims can be waived if release is knowing and voluntary)
Puentes v. United Parcel Serv., Inc., 86 F.3d 196 (11th Cir. 1996) (totality-of-the-circumstances test for voluntary and knowing waiver)
Myricks v. Fed. Reserve Bank of Atlanta, 480 F.3d 1036 (11th Cir. 2007) (negotiated releases support knowing, voluntary waiver)
Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (summary judgment standard for absence of material fact)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (summary judgment—standard for genuine issue of material fact)