Romero v. Allstate Insurance
Romero v. Allstate Insurance
Opinion of the Court
MEMORANDUM
From June 1, 2015 to June 17, 2015, the first of multiple jury trials was held in this case on the singular issue of whether ten of the Plaintiffs — Roger Boyd, Craig Crease, Ronald Harper, Mike Kearney, Sylvia Kelly, David Lawson, Ed Murray, Christopher Perkins, Rick Peterson, and Paula Reinerio — knowingly and voluntarily signed the Release of claims Allstate used in connection with the termination of Plaintiffs’ employment contracts as part of the Preparing for the Future Group Reorganization Program. The jury found that, as to eight of the Plaintiffs, the Release was not knowingly and voluntarily signed, but, as to the remaining two Plaintiffs,
Plaintiffs -also posed two other Release defenses: unclean hands and unconsciona-bility. These equitable defenses, however, were reserved .for ruling by the Court and were not submitted to the jury. Following the trial, the parties submitted hundreds of pages of proposed-findings of .fact and conclusions of law, together with thousands of pages,.of exhibits, pursuant to Rule 52(a)(1) of the Federal Rules of Civil Procedure. The Court now issues the following Memorandum on the remaining issues.
I. FINDINGS OF FACT
By way of brief review, this case revolves around Allstate’s announcement and implementation -of its Preparing for the Future Group Reorganization Program (“the Program”). Prior to November 1999, the majority of Allstate’s captive agency force acted as employee agents, under either an R830 or an R1500 contract, and was entitled to a wide range of company-sponsored health, welfare, and retirement benefits. On November 10, 1999, Allstate announced the Program by noting that,, as part of a new business model, it was reorganizing its entire captive agency force into a single exclusive agency independent contractor program. With few exceptions, Allstate terminated the employment contracts of the 6,200-plus R830 and R1500 employee agents effective no later than June 30, 2000.
In connection with the termination of the R830 and R1500 employment contracts, Allstate offered the agents working under those contracts four options. The first three options were conditioned upon the agents’ agreement to execute a release of claims (the “Release”), while the fourth
As to the remaining findings of fact, the Court remarks that this case has been in litigation for over fourteen years. The facts have been enumerated at length on multiple occasions and in numerous, extensive opinions from this Court. None of the trial evidence or testimony varied materially from these previous discussions.
II. CONCLUSIONS OF LAW
A. Whether the Release is Invalid Based op Unclean Hands
As a general principle, unclean hands is “a self-imposed ordinance that closes the doors of a court of equity to one tainted with inequitableness or bad faith
Plaintiffs now contend that the doctrine of unclean hands precludes Allstate from enforcing the Release. Allstate, on the other hand, argues that Plaintiffs have failed to prove that the Release is invalid based on unclean hands because: (1) the unclean hands doctrine does not apply to this case where Allstate is not asserting an equitable defense; and (2) Plaintiffs have failed to prove the unclean hands theory on its merits. The Court addresses each assertion individually.
1. Whether the Unclean Hands Theory Applies to this Case
Allstate first argues that the unclean hands doctrine is a defense that is available only to a party opposing a request for equitable relief. Allstate, however, does not request equitable relief, but rather only seeks to enforce a contract as an affirmative defense to Plaintiffs’ federal and state law claims. Thus, according to Allstate, the unclean hands doctrine cannot apply.
The Court previously addressed this argument in detail in the Memorandum Opinion of October 6,2014. Romero v. Allstate Ins. Co., 52 F.Supp.3d 715 (E.D.Pa. 2014). Specifically, in response to this precise argument, the Court held as follows:
This argument, however, disregards prevailing Third Circuit law. In Mente v. Chevrolet Oldsmobile, Inc. v. GMAC, 451 Fed.Appx. 214 (3d Cir. 2011), a jury awarded $4 million to the plaintiffs for the defendant’s breach of contract. Id. at 217. The defendant asserted at trial that the plaintiffs had waived their rights to sue the defendant in a Forbearance Agreement. Id. at 216-17. The jury found enforcement of the Forbearance Agreement was barred by the equitable doctrine of unclean hands. Id. at 217. On appeal, the defendant argued that the unclean hands doctrine did not apply because the plaintiffs claim was contractual and not equitable. Id. The Third Circuit disagreed and held that “the doctrine is being invoked to defend against GMAC’s request to enforce the waiver of [the plaintiffs] breach of contract claim in the Forbearance Agreement.*376 Under Pennsylvania law, a request to enforce a contractual waiver is a request for specific performance of the contract containing the waiver.” Id. at 217-18 (citing Griest v. Pa. State Univ. & Dickinson Sch. of Law, 897 A.2d 1186, 1186 (Pa.Super.Ct. 2006)). As specific performance is an equitable remedy, the Third Circuit found that it could be barred by the doctrine of unclean hands. Id. at 218. The court further rejected the argument that the doctrine of unclean hands can only be invoked by a defendant seeking to defeat a plaintiffs claim for affirmative equitable relief. Id. at 218 n. 4. In the present case, Plaintiffs bring multiple federal and state law claims in connection with the enactment of the Program and Release. Allstate has responded with the .defense that the claims were waived by the Plaintiffs’ signature of the Release. By doing so, Allstate now seeks specific performance of the Release to enforce the waiver of Plaintiffs’ claims, which is a request that sound in equity. In response, Plaintiffs may now properly assert the doctrine of unclean hands.
Id. at 735.
Allstate now attempts to argue that, notwithstanding this previous ruling, Mente is distinguishable and should not apply here. Allstate’s argument, however, is nothing more than a belated effort to seek reconsideration of a prior ruling. Local Rule of Civil Procedure 7.1(g) provides that a motion for reconsideration shall be filed within fourteen days of the order at issue. The Court’s prior opinion, in this case, was filed on October 6, 2014, almost a year prior to Allstate’s brief seeking reconsideration of that ruling. Accordingly, the Court declines to reconsider whether Mente is, in fact distinguishable.
Allstate raises the additional argument that Mente involved only the application of Pennsylvania law and, in this matter, the law of each Plaintiffs home state governs his or her unclean hands argument. Thus, according to Allstate, if Mente has any application here at all, it applies only to Pennsylvania Plaintiff Murray.
This argument also fails. Allstate seeks specific performance of the Release at issue — ie., to enforce the Release which bars suit for claims identical to those raised by Plaintiffs. Under the applicable state laws, it is well-established that any request for specific performance is a request for equitable relief to which a defense of unclean hands could apply. See, e.g., Matrix Fin. Servs., Inc. v. Dean, 288 Ga.App. 666, 655 S.E.2d 290, 294 (2007) (applying the law Georgia — the home state of Plaintiffs Harper, Perkins, and Peterson — and holding that specific performance of a waiver clause in a settlement agreement is equitable in nature, and the doctrine of unclean hands may bar such equitable relief); Pepsi-Cola Bottling Co. of Pittsburg Inc. v. Bottling Grp., LLC, No. Civ.A.07-2315, 2009 WL 873020, at *10 (D.Kan. Mar. 30, 2009) (applying the law of Kansas — the home state of Plaintiffs Crease and Kearney — to hold that enforcement of a settlement agreement is a request for equitable relief to which the unclean hands doctrine applies); Crafts v. Pitts, 161 Wash.2d 16, 162 P.3d 382, 386 n. 4 (2007) (applying the law of Washington— the home state of Plaintiff Boyd — and holding that the defense of unclean hands is available to any party against whom specific performance is sought); Busch v. Baker, 79 Fla. 113, 83 So. 704, 705 (1920) (applying the law of Florida — the home state of Plaintiff Kelly — and holding that a request for specific performance of a contract is decided by a court of equity and is subject to consideration of an unclean hands defense). Allstate has not identified for this Court any case from any relevant
2. Whether the Unclean Hands Doctrine Bars Enforcement of the Release
As stated above, the United States Supreme Court has remarked that the unclean hands doctrine is a “self-imposed ordinance that closes the doors of a court of equity to one tainted with inequi-tableness or bad faith relative to the matter in which he seeks relief[.]” Precision Instrument, 324 U.S. at 814, 65 S.Ct. 993. Although the various states’ laws at issue differ somewhat in their definitions of what constitutes “unclean hands,” there remains a general agreement that unclean hands applies not only-to fraudulent and illegal transactions, but also to unscrupulous practices, oppressive conduct, or uncon-scientious conduct. Crucially, • however, that conduct must bear on the subject of the litigation. See, e.g., Tribeca Lending Corp. v. Real Estate Depot, Inc., 42 So.3d 258, 262 (Fl.Dist.Ct.App. 2010) (noting that the unclean hands doctrine “applies not only to fraudulent and illegal transactions, but to any unrighteous, unconseientious, or oppressive conduct by one seeking equitable interference in his own behalf’) (internal quotation 'marks omitted); Terraciano v. Com., Dept. of Transp., Bureau of Driver Licensing, 562 Pa. 60, 753 A.2d 233, 237-38 (2000) (“The doctrine of unclean hands requires that one seeking equity act fairly and without fraud or deceit as to the controversy in issue.”); Ingram v. Kasey’s Assocs., 340 S.C. 98, 531 S.E.2d 287, 292 n. 2 (2000) (holding that a party will have unclean hands where the party behaves “unfairly in a matter that is the subject of the litigation to the prejudice of the defendant”); Whiten v. Murray, 267 Ga.App. 417, 599 S.E.2d 346, 352 (2004) (“The unclean-hands maxim which bars a complainant in equity from obtaining relief has reference to -an inequity which infects the cause of action so that to entertain it would be violative of conscience. It must relate directly to the transaction concerning which complaint is made.”); Green v. Higgins, 217 Kan. 217, 535 P.2d 446 (1975) (“The application of the clean hands doctrine is subject to certain limitations. Conduct which will render' a party’s hands unclean so as to deny him access to a court of equity must be willful conduct which is fraudulent, illegal or unconscionable... .Furthermore, the objectionable misconduct must bear an immediate relation to the subject-matter of the suit and in some measure affect the equitable relations subsisting between the parties to the litigation and arising out of.the transaction.”).
Plaintiffs now argue that they have presented compelling evidence that Allstate acted with unclean hands in connection with the Release. Without separately addressing each individual Plaintiff, they contend that the manner in which Allstate structured and implemented the Program involved a “bad faith and inequitable attempt to deny the 6,200 employee agents terminated under the Program with a de facto opportunity to challenge the legality of their termination.” (Pis.’ Proposed Findings of Facts & Conclusions of Law (“Pis.’ Proposed FOFCOL”) ¶210.) More specifically, Plaintiffs assert that, in the early 1980’s Allstate promised its employee agents job security and renewal commissions, conditioned on the employee agents’ investment of personal funds in order to grow their books of business. . As a result, many employee agents did, in fact,
Upon hearing all of the testimony, the Court agrees that Allstate’s conduct with respect to the Release and its inclusion in the Preparing for the Future Program was less than commendable. Undoubtedly, Allstate managers repeatedly represented to Plaintiffs that Allstate provided a “job for life” if Plaintiffs worked hard and grew their businesses. Moreover, the Court agrees that Allstate structured the Program in such a way as to exert some financial pressure on the employee agents to sign the Release and take one of the first three program options. Nevertheless, the fact remains that a party asserting an “unclean hands” defense must introduce “clear, convincing evidence of ‘egregious’ misconduct.” Citizens Fin. Grp., Inc. v. Citizens Nat’l Bank, 383 F.3d 110, 129 (3d Cir. 2004). “[T]here can be no question that proof by clear and convincing evidence is a more stringent standard than proof by a preponderance of the evidence.” U.S. v. Askari, 222 Fed.Appx. 115, 119 (3d Cir. 2007). To that end, the Court does not find that Plaintiffs have adduced sufficient evidence that Allstate’s conduct was so egregious as to constitute clear and convincing proof that they acted with unclean hands and should, in equity, be precluded from seeking enforcement of that Release.
Under the Older Workers Benefit Protection Act (“OWBPA”), an individual may not waive any right or claim under the ADEA unless the waiver is knowing and voluntary. 29 U.S.C. § 626(f). A waiver may not be considered knowing and voluntary unless “at a minimum” the waiver satisfies a number of specific statutory requirements. Id. Conversely stated, the use of a Release in the termination of an employee may be entirely proper unless it fails to meet the minimum statutory requirements set forth in OWBPA or if the Release was not signed knowingly and voluntarily. As set forth in great detail in this Court’s other opinions, the Release in this case met the statutory requirements under OWBPA. Moreover, as to two of the Plaintiffs in this case, the jury found that the Release was signed knowingly and voluntarily, thereby undermining Plaintiffs’ attempt to establish that Allstate acted with unclean hands and should be precluded from enforcing the Release as to those Plaintiffs.
As to the remaining eight Plaintiffs as to whom the jury found the Release was not
In short, the Court finds a great deal of evidence on both sides of this issue. On one hand, Allstate established that the Program and Release were business-related decisions that complied fully with federal statutory law and which made an effort to effectuate valid cost-savings measures while simultaneously offering employee agents alternative choices to preserve their financial futures. On the other hand, Plaintiffs presented some proof that Allstate acted out of an unscrupulous and objectionable desire to preserve its profits, substantially cut the costs of remunerating its workforce, and then attempted to insulate itself from liability by way of the Release. When placed on a scale, the parties’ evidence balances somewhat evenly and, at times, tips ever so slightly in favor of Plaintiffs in terms of shocking the Court’s moral sensibilities. Under the clear and convincing standard, however, that is not enough to persuade the Court that enforcement of the Release will undermine this Court’s integrity. See Gaudiosi v. Mellon, 269 F.2d 873, 882 (3d Cir. 1959) (noting that the unclean hands doctrine is primarily intended to protect the Court’s integrity where the conduct of a party shock’s the judge’s moral sensibilities; it has nothing to do with the rights or liabilities of the parties). As such, the Court must find that Allstate is entitled to judgment on Plaintiffs’ unclean hands defense.
B. Whether the Release is Unconscionable
The second question before the Court is whether Plaintiffs have estab
1. Procedural Unconscionability
“Procedural unconscionability examines the process leading to the formation of the contract and the form and language of the' agreement.” Porreca v. Rose Grp., No. Civ.A.13-1674, 2013 WL 6498392, at *7 (E.D.Pa. Dec. 11, 2013). A procedurally unconscionable contract bears a lack of meaningful choice in the acceptance of the challenged provision. Quilloin, 673 F.3d at 235; see also Zuver v. Airtouch Commc’ns, 153 Wash.2d 293, 103 P.3d 753, 759 (2004) (“Procedural unconscionability is the lack of meaningful choice, considering all the circumstances surrounding the transaction including the manner in which the contract was entered, whether each party had a reasonable opportunity to understand the terms of the contract, and whether the important terms [were] hidden in a maze of fine print”) (internal quotations and quotation marks omitted); Wisconsin Auto Title, 714 N.W.2d at 165-66 (“Determining whether procedural un-conscionability exists requires examining factors that bear upon the formation of the contract, that is, whether there was a “real and voluntary meeting of the minds” of the contracting parties. The factors to be considered include, but are not limited to, age, education, intelligence, business acumen
In the present case, Plaintiffs argue that the Release was procedurally unconscionable based 'on three factors. First, they assert that the relative bargaining power of the parties reveals that Allstate was in a significant position of dominance. Second, they assert that' the Release was essentially a take-it-or-leave it adhesion contract that allowed Plaintiffs no bargaining room. Finally, they claim that Plaintiffs were forced into the Release by a large degree of economic compulsion.
Having considered all ‘of the testimony and evidence at trial, however, the Court does not find that Plaintiffs have met their burden of proving that the Release was procedurally unconscionable, even as to those Plaintiffs deemed by the jury to have not signed the Release knowingly, and voluntarily. As to the first two factors identified by,.Plaintiffs, it is undisputed that the Release was drafted entirely by Allstate, that Allstate had significantly greater bargaining power,,and that the Release was a standardized contract that did not allow for any alterations to be made by Plaintiffs. In other ¡words,, it was a classic adhesion contract.
The third factor identified by Plaintiffs causes the Court somewhat greater hesitation, particularly in light of the jury’s finding that certain Plaintiffs did not “voluntarily” enter into the Release based on the degree of economic compulsion imposed upon them. While the Plaintiffs in this case undoubtedly faced various economic pressures resulting from Allstate’s corporate restructuring, this Court’s own consideration of the evidence does not, however, suggest that the Release as a whole so deprived Plaintiffs of a meaningful choice as to render the entire agreement procedurally unconscionable. Rather, Plaintiffs had some choice of signing the Release and taking one of three fairly lucrative options with Allstate, or not signing the Release and taking only a base severance pay. The power imbalance and economic compulsion in this case was not so much more drastically striking than in the typical employer-employee context. While not signing the Release and facing the loss of both employment and investments may not have offered a preferable or economically-satisfying alternative to signing the Release and obtaining the incentives offered, the fact remains that Plaintiffs, who were business-sawy individuals, retained the viable option to not sign the Release, seek alternative employment with a base severance payment in hand, and bring suit against Allstate. See generally Quilloin, 673 F.3d at 236-37 (distinguishing cases where the plaintiffs were either a minimally-educated crane operator
Considering all of these factors in conjunction, the Court simply cannot find that
2. Substantive Unconscionability
The analysis of substantive un-conscionability requires “looking at the contract terms and determining whether the terms are ‘commercially reasonable,’ that is, whether the terms lie outside the limits of what is reasonable or acceptable. The issue of unconscionability is considered ‘in the light of the general commercial background and the commercial needs.’ ” Wisconsin Auto Title, 714 N.W.2d at 166. “Substantively unconscionable terms are those that are unreasonably or grossly favorable to one side and to which the disfavored party does not assent.” Porreca, 2013 WL 6498392, at *10 (quoting Estate of Hodges v. Meadows, No. Civ.A.12-1698, 2013 WL 1294480, at *6 (E.D.Pa. Mar. 29, 2013). “Substantivé unconscionability focuses on the one-sidedness, unfairness, unreasonableness, harshness, overreaching, or oppressiveness of the provision at issue.” Wisconsin Auto Title, 714 N.W.2d at 171; see also Cronin v. Citifinancial Servs., Inc., No. Civ.A.08-1523, 2008 WL 2944869, at *3 (E.D.Pa. July 26, 2008) (“To establish substantive unconscionability, the plaintiff must show that the contract terms are unreasonably favorable to the drafter and that the other party had no meaningful choice but to accept those terms.”); Mullis, 505 S.E.2d at 820 (“As to the substantive element of unconscionability, courts have focused on matters such as the commercial reasonableness of the contract terms, the purpose and effect of the terms, the allocation of the risks between the parties, and similar public policy concerns.”); Gainesville Health Care Ctr., 857 So.2d.at 284 (“To determine whether a contract is substantively unconscionable, a court must look to the terms of the contract, itself, and determine whether they are so ‘outrageously unfair’ as to ‘shock the judicial conscience.’”); Zuver, 103 P.3d at 759 (“Substantive- unconscionability involves those cases where a clause or term in the contract is alleged to be one-sided or overly harsh.” “‘Shocking to the conscience’, ‘monstrously harsh’, and ‘exceedingly calloused’ are terms sometimes used to define substantive unconscionability.”). .
Plaintiffs advance several arguments in support of their substantive un-conscionability contention. First, they assert that Allstate promised Plaintiffs job security and induced Plaintiffs to invest their personal funds in reliance on those promises. Subsequently, Allstate structured the Program so that Plaintiffs would face imminent unemployment, together with the loss of their investments and the prospect of multiple non-compete clauses, unless they signed the Release in order to take advantage of one of the- three Release-based options in the Program.
Such an argument, however, does not convince the Court to make the drastic finding that the Release was so outrageously unfair as to be substantively unconscionable. As noted previously, the Court recognizes that Allstate managers repeatedly made oral promises that a job with Allstate was akin to a “job for life.” Moreover, Allstate repeatedly encouraged their employee agents to invest in their agencies in order to grow their business and expand their profits. The fact remains, though, that the written employment con
Second, Plaintiffs assert that there was a gross disparity between the benefits Allstate gained from the Release and any benefits the Release conferred- on Plaintiffs. Specifically, they contend that Allstate gained, the benefit of the continued services of, thousands of Allstate agents without having to provide them with benefits or expense reimbursements — thereby saving hundreds of millions of dollars— while employee agents who executed the Release found themselves in a far worse position as a result of the Program. As such, Plaintiffs aver that the Release is substantively unconscionable because of the gross disparity in what each party gained and gave up by executing it.
This argument is completely inapposite as it makes an improper comparison between what Plaintiffs had before and after the Program, as opposed to what Plaintiffs had if they signed the Release and if they did not sign the Release. Allstate completely terminated the R830 and R1500 contracts and, thus, no longer had the obligation to provide Plaintiffs with benefits and reimbursements, regardless of whether Plaintiffs signed the Release or not. The question of whether that termination was legally wrongful was not at issue in this trial. Rather, the proper question here is whether the Plaintiffs’ surrender of their right to sue Allstate was grossly disparate to the consideration Allstate offered to Plaintiffs under the Program. The Court finds that it was not. Indeed, had the majority of the employee agents opted to take the enhanced severance option or the conversion option, Allstate could have faced the payout of millions of dollars to such agents in exchange for only the Release, without the benefit of the agents’ continued service. Accordingly, the Court- cannot deem the contract “monstrously harsh” or “exceedingly calloused.”
Finally, Plaintiffs argue that public policy considerations support a finding of unconscionability. They claim that “it contravened public policy for Allstate to condition Plaintiffs’ ability to continue their agency relationship with the company (doing the same job, but without security or benefits), or to liquidate the personal investments they had made into the business at Allstate’s behest, on a waiver of their rights, including under federal remedial employment statutes.” (Pis.’ Proposed FOFCOL ¶ 261.)
This argument again raises the wrong question. Irrespective of the Release, all R830 and R1500 contracts were terminated. . Plaintiffs do not now contend that it was against public policy for Allstate to terminate their employment contracts. Indeed, Allstate was entitled — as many companies do — to engage in mass termination
In short, the Court’s judicial conscience is not shocked by the Release at issue in this case. While the Court sympathizes with Plaintiffs’, undesirable predicament caused by Allstate’s decision to implement such a sweeping termination of its employee agent contracts;- the use of the Release in exchange for allowing Plaintiffs to obtain one of several lucrative options under the Program — albeit not an admirable tactic by a large, and profitable company — is not unreasonably, harsh, overreaching, or unfair. Thus,, the Court declines to deem the Release substantively unconscionable.
3. Conclusion as to Unconscionability
As set forth in detail above, the Release at issue, with respect to the ten 'named trial Plaintiffs, is neither procedurally nbr substantively unconscionable. In turn, the Release cannot be invalidated on this ground.
C. Conclusion as to Issues Before the Court
Based on the evidence at trial and the parties’ subsequent briefing, the Court rejects Plaintiffs’ unclean hands and uneon-scionability defenses as to the ten trial Plaintiffs. Given the fact that this trial was only the first of many trials to be held on the issue of the Release in this matter, this ruling shall have no bearing on these identical issues in the future Release trials.
A Judgment Order follows.
. The jury concluded that Plaintiffs Perkins and Murray knowingly and voluntarily signed the Release.
. The Court acknowledges that the ten individual trial Plaintiffs offered testimony about their unique circumstances, which has not previously been discussed in detail. Notably, however, Plaintiffs' Proposed Findings of Fact and Conclusions of Law, in large part, disregard the npances in their testimony and argue for the application of both unclean hands and unconscionability generally. As Plaintiffs are the proponents of these two defenses, the Court follows their lead and analyzes these issues without detailed consideration of their individual circumstances.
. The ten trial Plaintiffs in this case come from seven different states: Pennsylvania, South Carolina, Kansas, Washington, Wisconsin, Georgia, and Florida. The Court attempts to draw a sampling of cases from these states when discussing a particular point of law. To the extent the law is the same among the states, however, the Court will not cite to a case from each jurisdiction on each legal proposition.
. This legal finding is made only with respect to this Memorandum and shall not impact Plaintiffs' ability to prove otherwise if and when this case proceeds to the substantive merits of the underlying claims.
. A contract of adhesion has been defined as "a standardized contract offered on a ‘take it or leave it’ basis and under such conditions that a consumer cannot obtain the desired product or service except by acquiescing in the form contract.” Realty Lenders, Inc. v. Levine, 286 Ga.App. 326, 649 S.E.2d 333, 336 (2007) (quotation omitted); see also Mendez v. Palm Harbor Homes, 111 Wash.App. 446, 45 P.3d 594, 602 (2002) (holding that generally, an adhesion contract is prepared on standard printed form, is prepared by one party and submitted to the other on a "take it or leave it basis,” and there is "no true equality of bargaining power between the parties.”).
. One of the cases distinguished in Quilloin was a case relied upon by Plaintiffs— Alexander v. Anthony Int'l L.P., 341 F.3d 256, 266 (3d Cir. 2003). For the same reasons that the Quilloin court found Alexander to be not probative — i.e., the fact that the Alexander plaintiffs were crane operators with limited education and "at best, narrow options for other employment” — this Court finds that case distinguishable from the one at bar.
Reference
- Full Case Name
- Gene R. ROMERO v. ALLSTATE INSURANCE COMPANY
- Cited By
- 7 cases
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- Published