11th Circuit Enforces Arbitration Agreement Barring Class Actions

Interpreting Georgia law, the U.S. Court of Appeals for the 11th Circuit rejected the argument that an employer's dispute resolution policy was unconscionable because it prohibited class actions.  Caley v. Gulfstream Aerospace Corp.  The Court held that the class action bar served arbitration's goals of simplicity, informality, and expedition embraced by the Supreme Court in Gilmer v. Interstate/Johnson Lane Corp, 500 U.S. 20 (1991).  The Court acknowledged that the 9th Circuit had held otherwise in Ingle v. Circuit City Corp., 328 F.3d 1165 (2003), but reasoned that California and Georgia law differed in their approaches to unequal bargaining contracts.