Brooks v. Cintas Corp.

Summary

The Fifth Circuit affirmed orders compelling arbitration and denying reconsideration of an arbitration award in Nicholas Brooks’s Title VII race-discrimination and retaliation action against Cintas Corporation. The court held that Brooks’s alleged failure by Cintas to confer or mediate did not waive the arbitration provision and that the arbitrator’s credibility determinations did not establish partiality, corruption, or another permissible basis for vacatur. The opinion is unpublished and nonprecedential under Fifth Circuit Rule 47.5, subject to limited exceptions.

Holdings

1. The district court properly compelled arbitration because Brooks conceded that he agreed to arbitrate the dispute, and Cintas's alleged refusal to confer or mediate was at most a breach of the employment agreement that did not constitute an external legal constraint barring arbitration.
2. The district court properly refused to vacate or reconsider the arbitration award because Brooks failed to show arbitrator partiality or corruption, and an arbitrator's decision not to credit evidence is not independently reviewable.

Questions Presented

1. Whether the district court properly compelled arbitration despite Cintas's alleged refusal to confer or participate in mediation.
2. Whether the arbitrator's alleged failure to credit Brooks's evidence demonstrated partiality or another legally sufficient basis to vacate the arbitration award.
3. Whether the district court properly denied Brooks's motion to reopen the administratively closed case and reconsider the arbitration award.

Disposition

affirmed