On April 1, 2009 the U.S. Supreme Court found that a collective bargaining provision that requires employees to arbitrate age discrimination claims is enforceable. While the issue in 14 Penn Plaza LLC v. Pyett involved age discrimination, it is likely that employers in union environments could also require employees to arbitrate other types of discrimination and workforce claims. The Court was clear, however, that in order to use arbitration and avoid litigation, the employer and union must have “clearly and unmistakably” agreed that grievance and arbitration procedures must be used. Although there are still unresolved issues, the decision makes clear that the Court views arbitration as an acceptable means to address employment disputes.