In a recent decision, Judge Young of the U.S. District Court for the District of Massachusetts held that an arbitration agreement does not need to specifically reference the Massachusetts Payment of Wages Law in order for claims under that statute to be subject to arbitration. Specifically, the district court held that any such requirement would be preempted by the Federal Arbitration Act (FAA).
In Awuah v. Coverall N. Am., Inc., the court first considered whether Massachusetts law required that an arbitration agreement specifically mention the Massachusetts Payment of Wages Law, Mass. Gen. Laws ch. 149, § 148, to be enforceable as to claims under that statute. The court noted that, in Crocker v. Townsend...
