Sniezek v. Kansas City Chiefs Football Club
402 S.W.3d 580
Mo. Ct. App.2013Background
- Chiefs appeal denial of motion to compel arbitration for Brenda Sniezek's age discrimination claim.
- Sniezek signed an arbitration Agreement on her first day of work, January 18, 1982, while starting March 8, 1982 as an at-will employee.
- The Agreement required Sniezek to refer disputes to the NFL Commissioner and released numerous NFL and Chiefs entities from actions, with the Commissioner’s decision deemed final.
- Sniezek worked for nearly 29 years and was terminated in January 2011 at age 51.
- Sniezek filed a Missouri Human Rights Commission claim and later a circuit court damages action under the Missouri Human Rights Act.
- The circuit court denied the Chiefs’ motion to compel arbitration; the Chiefs appeal, arguing the Agreement is a valid arbitration contract.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does the Agreement constitute a valid arbitration contract? | Chiefs contend mutual promises create consideration. | Chiefs argue the NFL incorporation provides mutual arbitration. | No valid arbitration contract; no mutual consideration by Chiefs. |
| Did Sniezek's at-will employment and later signing create consideration for arbitration? | Arbitration was supported by continued at-will employment as consideration. | Continued at-will employment after offer does not prove Chiefs’ promise to arbitrate. | Continued at-will status after signing did not constitute valid consideration. |
| Is the NFL constitution and bylaws incorporation sufficient to bind the Chiefs to arbitration? | Incorporation shows mutual obligation to arbitrate. | Incorporation does not import mutual promises by the Chiefs to arbitrate. | |
| Incorporation did not bind Chiefs to arbitration; only Sniezek promised. |
Key Cases Cited
- Morrow v. Hallmark Cards, Inc., 273 S.W.3d 15 (Mo.App. 2008) (contracts require offer, acceptance, and consideration)
- Nitro Distrib. v. Dunn, 194 S.W.3d 339 (Mo. banc 2006) (apply state contract law to determine validity of arbitration clause)
- Frye v. Speedway Chevrolet Cadillac, 321 S.W.3d 429 (Mo.App. 2010) (consideration and contract principles govern arbitration validity)
- Whitworth v. McBride & Son Homes, Inc., 344 S.W.3d 730 (Mo.App. 2011) (reaffirms need for valid consideration for arbitration contracts)
- Dunn Indus. Group, Inc. v. City of Sugar Creek, 112 S.W.3d 421 (Mo. banc 2003) (usual contract principles apply to arbitration agreements)
- Johnson v. McDonnell Douglas Corp., 745 S.W.2d 661 (Mo. banc 1988) (essential elements of contract: offer, acceptance, consideration)