Equal Employment Opportunity Commission v. American Express Publishing Corp.
The Equal Employment Opportunity Commission (EEOC) filed an action against American Express Publishing Corporation, alleging age discrimination in the termination of J. Stewart Lahey's employment, violating the ADEA. American Express moved for summary judgment, arguing Lahey had released his ADEA claim by signing an agreement for severance pay. A previous summary judgment motion was denied due to factual issues regarding the knowing and voluntary nature of the release. The court, applying factors such as Lahey's education, time to review the agreement, role in negotiation, and clarity of terms, found that while some factors favored dismissal, significant factual disputes remained. These disputes include the actual time Lahey possessed the release, whether he genuinely negotiated its terms, and the extent and understanding of the consideration received. Therefore, the court denied American Express's renewed motion for summary judgment, concluding these issues require a trial.