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Blount v. JEH Johnson

August 5, 2020

A settlement agreement was entered into order to resolve multiple claims of violations of an employee’s equal employment opportunity.  Prior to executing the settlement agreement, the employee learned of another equal employment opportunity claim – that the employee had not been selected for a particular job opportunity.  Despite learning of another claim, with the advice of counsel, the employee executed the settlement agreement.
The settlement agreement specified that the agreement would “settle all matters, claims, or causes of action arising from or related to employment . . . as of the date of the signing of the Agreement, including but not limited to all claims [previously] raised.”  After executing the agreement, the employee filed a claim for the action he learned of relating to the job opportunity.  The employer filed a motion to dismiss.
The United States District Court for the District of Columbia examined the settlement agreement and concluded that the employee had waived the claim.  Specifically, the Court held that “[t]he Settlement Agreement waived any actions based on events that had taken place before the date of its execution, without regard to whether . . . [the employee] was aware of them at the time . . . [and that the] current expression of misunderstanding is untenable.”