Morrow v. Hallmark Cards, Inc.

Although I do not necessarily disagree with what is written in the majority opinion, I believe this case can be decided on somewhat narrower grounds, without addressing all of the issues the majority discusses. I accordingly concur in the result.

To my mind, two provisions of Hallmark’s Dispute Resolution Program, appearing in the policy’s first two pages, defeat its argument that the policy created an enforceable arbitration contract. First, on its opening page the policy states: “This procedure does not change the employment-at-will relationship between the Company and its employees.” On the…