In 1999, American Golf Corporation (AGC) hired Heye for a job in the pro shop at the Paradise Hills Golf Course, a club that it managed. AGC gave Heye a number of documents, including the Co-Worker Alliance Handbook. On page 20 of the handbook was a reference to arbitration that essentially stated that binding arbitration would be the exclusive means of resolving all disputes about unlawful harassment, discrimination, wrongful discharge, and other causes of action and that the employee was agreeing to waive her right to pursue such claims in court. Page 23 of the handbook contained the following acknowledgment: My signature below indicates that I have read this AGC Co-Worker Alliance agreement and handbook and promise and agree to abide by its terms and conditions.
I further understand that the Company reserves the right to amend, supplement, rescind or revise any policy, practice, or benefit described in this handbook-other than employment at-will provisions-as it deems appropriate. I acknowledge that my employment is at-will, which means that either the Company or I have the absolute right to end the employment relationship at any time with or without notice or reason. I further understand that the president of American Golf Corporation is the only authorized representative of the Company who can modify this at-will employment relationship and the contents of this handbook, and that any such modifications must be made in writing. I further acknowledge that I have read and agree to be bound by the arbitration policy set forth on page 20 of this handbook. Heye signed the acknowledgment. Heye worked for AGC until January 2000. She later sued AGC on a variety of grounds, including sex discrimination and sexual harassment. AGC moved to compel arbitration under the acknowledgment form that Heye signed. Was the arbitration agreement supported by consideration?