Craig Zuber v. Boscovs, 871 F.3d 255

Zuber, a Boscov’s employee, was injured at work on August 12, 2014, filed a workers’ compensation claim, took medical leave, returned, and was later terminated on September 10, 2014.
On April 8, 2015, Zuber and Boscov’s executed a Compromise and Release Agreement (C&R) approved by the Pennsylvania Workers’ Compensation Office, resolving the August 12, 2014 workers’ compensation claim.
On July 9, 2015, Zuber sued under the FMLA (failure to notify, failure to designate leave, and retaliation) and alleged Pennsylvania common-law retaliation for filing a workers’ compensation claim.
Boscov’s moved to dismiss, arguing the C&R constituted a general release that waived Zuber’s FMLA and state-law claims; the District Court granted dismissal relying on its reading of paragraph 19 of the C&R.
The key contractual language at issue (paragraph 19) described the C&R as a "full and final resolution" of the 8/12/2014 work injury claim and relinquished rights to seek benefits or monies "for or in connection with" that work injury and other work injury claims through a specified date.
The Third Circuit reversed, holding the C&R was a specific workers’-compensation release and did not bar Zuber’s FMLA or Pennsylvania common-law claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the C&R waived Zuber’s FMLA claims	Zuber: C&R releases only workers’ compensation claims/benefits; it does not waive FMLA or common-law retaliation claims	Boscov’s: Paragraph 19 is a broad general release covering all claims arising from the injury, thus waiving FMLA and state-law claims	Court: C&R is an unambiguous, specific release of workers’ compensation claims/benefits only; does not bar FMLA or common-law claims
Proper law and method for interpreting the C&R	Zuber: Pennsylvania contract law controls; unclear terms should not be read to waive statutory rights absent clear language	Boscov’s: same choice of law but argues the contract language is sufficiently broad under Pennsylvania law	Court: Pennsylvania contract law applies; when contract is unambiguous, intent is derived from the document itself — here language is not broad enough to cover FMLA/common-law claims

Mazzella v. Koken, 739 A.2d 531 (Pa. 1999) (settlement enforceability governed by contract principles)
DIRECTV, Inc. v. Imburgia, 136 S. Ct. 463 (2015) (contract interpretation governed by state law unless preempted)
Restifo v. McDonald, 230 A.2d 199 (Pa. 1967) (release covers only what parties fairly contemplated)
Kripp v. Kripp, 849 A.2d 1159 (Pa. 2004) (clear contract terms supply parties’ intent; ambiguities allow parol evidence)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (plausibility standard for pleadings)
Fowler v. UPMC Shadyside, 578 F.3d 203 (3d Cir. 2009) (standard of review for Rule 12(b)(6) dismissal)