Gregory v. Derry Township School Dist., 2010 U.S. Dist. LEXIS 1875 (M.D. Pa. Jan. 10, 2010)

Court holds that the resigning teacher's execution of a general release barred her subsequent employment discrimination claims.

In Gregory, a teacher filed a race discrimination lawsuit against her former employer, co-workers, union officials, and the parent of one of her students after her resignation. At the time of the plaintiff's resignation, she executed a release which provided her with medical benefits and a favorable letter of reference. The plaintiff, in bringing her race discrimination claims, argued that the release was invalid in that she signed it under "extraordinary pressure and duress." In upholding the validity of the release, the court determined that the release was clear and unambiguous and the plaintiff had the requisite education to understand the terms of the release. In addition, the court noted that the plaintiff was free to consult with legal counsel prior to executing the release and union officials negotiated the release on her behalf. Although the court noted that the employer did not encourage the plaintiff to take the release home with her, her testimony at the evidentiary hearing demonstrated that she knowingly and voluntarily signed the release.

Case Law Alert - 1st Qtr 2010