The Fifth Circuit Court of Appeals recently ruled on an arbitration provision in an employee handbook. Carey v. 24 Hour Fitness, USA, Inc., No. 10-20845 (5th Cir. Jan. 25, 2012), available at http://www.ca5.uscourts.gov/opinions/pub/10/10-20845-CV0.wpd.pdf. The defendant employer issued an employee handbook that contained a provision requiring all employment-related disputes to be resolved through arbitration. The plaintiff employee signed an acknowledgment indicating that he received the handbook.