Summary
The Seventh Circuit affirmed the denial of SP Plus Corporation's request to compel arbitration or stay the plaintiff's wage-law action. The court held that SP Plus forfeited any opportunity for an evidentiary hearing by failing to respond in the district court to the plaintiff's affidavit disputing that he assented to arbitration, and that the record did not clearly establish formation of an arbitration agreement.
Topics
Practice areas
Questions Presented
- Whether the district court's order lifting the stay and denying arbitration was appealable under 9 U.S.C. § 16(a)(1).
- Whether SP Plus forfeited any right to an evidentiary hearing by failing to identify the factual dispute or request a hearing in the district court.
- Whether the record established that Carter formed an agreement to arbitrate.
- Whether federal policy favoring arbitration permits courts to apply rules more favorable to arbitration agreements than to ordinary contracts.
Holdings
- The order was appealable because, in light of SP Plus's failure to request a hearing or present responsive evidence below, it conclusively denied the request for arbitration rather than merely postponing the decision.
- SP Plus forfeited any opportunity for a hearing by failing to identify the evidentiary dispute or request a hearing in the district court.
- The record did not establish that Carter agreed to arbitrate, and the district court's conclusion was not clearly erroneous.
- Federal law requires arbitration agreements to be treated as enforceable as other contracts, but does not permit courts to favor arbitration over litigation or devise special rules favoring arbitration.
Key quotations
“Whether someone has agreed to arbitrate is a question for the court rather than the arbitrator” (at 4)
“arbitration agreements as enforceable as other contracts, but not more so.” (at 5)
“The federal policy is about treating arbitration contracts like all others, not about fostering arbitration.” (at 5)
Factual background
SP Plus relied on a checked box and initials in an electronic onboarding document titled "Mutual Agreement to Arbitrate All Claims" to argue that Carter agreed to arbitration. Carter submitted an affidavit stating that a human-resources employee completed and signed most of the onboarding forms for him, did not explain them, did not offer him an opportunity to decline, and did not allow him to view the computer screen displaying the choices. SP Plus did not submit contrary evidence or request an evidentiary hearing in the district court.
Procedural history
Carter filed an action based on state and federal minimum-wage statutes. The district court initially stayed the action in favor of arbitration based on an electronic onboarding form, but later reconsidered that ruling after Carter submitted an affidavit stating that a human-resources employee completed and signed the forms for him without explaining them or giving him an opportunity to decline. The district court lifted the stay and denied SP Plus's motion. SP Plus appealed without requesting an evidentiary hearing or presenting responsive evidence in the district court.