The Bridge Strategy & Technology Consulting, LLC v. Josh Adams

Summary

The Texas Court of Appeals for the Second Appellate District reversed the denial of an employer’s motion to compel arbitration in a dispute over unpaid cash and stock commissions. The court held that the employment agreement’s arbitration clause, governed by the Federal Arbitration Act, encompassed the former employee’s breach-of-contract and quantum-meruit claims. The court remanded for the trial court to compel arbitration and stay the proceedings.

Holdings

1. The Federal Arbitration Act preempts Georgia Code section 9-9-2(c)(9) insofar as it would require the parties' FAA-governed employment arbitration clause to be initialed before enforcement.
2. Adams's breach-of-contract and quantum-meruit claims for unpaid cash and stock commissions fell within the scope of the arbitration agreement.
3. The trial court was required to stay litigation involving Adams's arbitrable claims pending completion of arbitration.

Questions Presented

1. Whether the Federal Arbitration Act preempted Georgia Code section 9-9-2(c)(9), which requires an employment arbitration clause to be initialed by all signatories.
2. Whether Adams's breach-of-contract and quantum-meruit claims concerning unpaid cash and stock commissions fell within the scope of the arbitration clause.
3. Whether the trial court was required to stay the litigation pending arbitration under the Federal Arbitration Act.

Disposition

reversed_and_remanded