Devon Jackson-Felder v. Acima Credit, LLC

Summary

The United States District Court for the Northern District of Georgia overruled Plaintiff Devon Jackson-Felder’s objections and adopted the magistrate judge’s report and recommendation. The court held that federal-question and supplemental jurisdiction existed, that the parties had a valid arbitration agreement covering the claims, and that arbitrability questions were delegated to the arbitrator. The court granted Acima Credit, LLC’s motion to compel arbitration, denied the motions to remand, stayed the case, and administratively closed it.

Holdings

1. The district court may exercise supplemental jurisdiction over Jackson-Felder's state-law claims because they arise from a common nucleus of operative fact with his FCRA claim, and Jackson-Felder failed to show that the state-law claims substantially predominated or that exercising supplemental jurisdiction would be an abuse of discretion.
2. An incorrect ZIP code on the envelope used to mail the notice of removal, standing alone, did not require remand where Jackson-Felder did not show that he failed to receive written notice or suffered prejudice.
3. The contract's forum-selection clause did not preclude the district court's exercise of subject-matter jurisdiction or independently require remand.
4. The parties entered into a valid arbitration agreement that covers Jackson-Felder's claims.
5. The arbitration agreement clearly and unmistakably delegated gateway questions of arbitrability, including whether to arbitrate and whether Acima waived arbitration, to the arbitrator.

Questions Presented

1. Whether the district court could exercise federal-question and supplemental jurisdiction over Jackson-Felder's FCRA and related state-law claims.
2. Whether an incorrect ZIP code on the envelope used to mail the notice of removal required remand.
3. Whether the contract's forum-selection clause affected the district court's subject-matter jurisdiction or required remand.
4. Whether the parties entered into a valid and applicable arbitration agreement covering Jackson-Felder's claims.
5. Whether the arbitration agreement clearly and unmistakably delegated gateway questions of arbitrability, including waiver and whether to arbitrate, to the arbitrator.
6. Whether the case should be stayed pending arbitration.

Disposition

other