Gayfer Montgomery Fair Co. d/b/a Dillard's v. Austin

Summary

The Supreme Court of Alabama reviewed the denial of an employer's motion to compel arbitration of an employee's retaliatory-discharge claim. The court held that the arbitration agreement was not unconscionable because the employee failed to show terms grossly favorable to the employer, and it addressed whether the employment relationship involved interstate commerce under the Federal Arbitration Act.

Holdings

1. The arbitration agreement was not shown to be unconscionable. Under Alabama law, unconscionability requires both terms grossly favorable to a party with overwhelming bargaining power and proof of the relevant bargaining-power disparity; Austin failed to prove that the arbitration rules contained terms grossly favorable to Dillard's.
2. Austin's employment as a sales associate for Dillard's involved commerce within the meaning of the Federal Arbitration Act.
3. Austin agreed to be bound by Dillard's arbitration rules by signing the acknowledgment and continuing her employment.

Questions Presented

1. Whether the employer's arbitration agreement was unconscionable because the employee had suffered a workplace injury before signing it.
2. Whether the employee's employment and the arbitration agreement involved or substantially affected interstate commerce under the Federal Arbitration Act.
3. Whether the employee agreed to be bound by the arbitration rules by signing the acknowledgment and continuing her employment.
4. Whether the trial court should have stayed the state proceedings pending resolution of the employer's federal petition to compel arbitration.

Disposition

reversed_and_remanded