Summary
The United States District Court for the Eastern District of Texas considers Ruiz Food Products, Inc.’s motion to stay the case and compel arbitration of Dahlia Doggins’s 42 U.S.C. § 1981 racial-discrimination claim. The court applies the Federal Arbitration Act and Texas contract law, concluding that the arbitration agreement is valid, non-illusory, and not modified by the employee handbook acknowledgment form. The motion to stay and compel arbitration is granted.
Holdings
- The FAA governs procedural matters concerning the arbitration agreement because the agreement expressly states that it is governed by the FAA.
- The parties entered into a valid arbitration agreement under Texas law.
- The Handbook Acknowledgment Form did not incorporate or modify the arbitration agreement.
- The arbitration agreement was not illusory and was enforceable under Texas law.
- Plaintiff's § 1981 racial-discrimination claim falls within the arbitration agreement's scope.
Questions Presented
- Whether the Federal Arbitration Act governs procedural questions concerning the arbitration agreement.
- Whether the parties formed a valid and enforceable arbitration agreement under Texas contract law.
- Whether the Handbook Acknowledgment Form incorporated or modified the arbitration agreement.
- Whether the arbitration agreement was illusory because the employer could allegedly modify or revoke it.
- Whether Plaintiff's 42 U.S.C. § 1981 racial-discrimination claim falls within the scope of the arbitration agreement.
Disposition
other
Cases Cited (39)
- Henry Schein, Inc. v. Archer & White Sales, Inc., 586 U.S. 63, 65 (2019)(followed)
- Volt Info. Scis., Inc. v. Bd. of Trs. of Leland Stanford Junior Univ., 489 U.S. 468, 478 (1989)(followed)
- CompuCredit Corp. v. Greenwood, 565 U.S. 95, 97-98 (2012)(followed)
- Moses H. Cone Mem'l Hosp. v. Mercury Constr. Corp., 460 U.S. 1, 24 (1983)(followed)
- Dean Witter Reynolds, Inc. v. Byrd, 470 U.S. 213, 219, 221 (1985)(followed)
- Lloyd's Syndicate 457 v. FloaTEC, L.L.C., 921 F.3d 508, 516 n.5 (5th Cir. 2019)(followed)
- Will-Drill Res., Inc. v. Samson Res. Co., 352 F.3d 211, 214 (5th Cir. 2003)(followed)
- United Steelworkers of Am. v. Warrior & Gulf Nav. Co., 363 U.S. 574, 582-83 (1960)(followed)
- Prima Paint Corp. v. Flood & Conklin Mfg. Co., 388 U.S. 395, 404 n.12 (1967)(followed)
- Kubala v. Supreme Prod. Servs., Inc., 830 F.3d 199, 201-02, 204 (5th Cir. 2016)(followed)
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