Stephens v. Greensky, LLC

Summary

The United States District Court for the Northern District of Georgia grants Greensky, LLC’s motion to compel arbitration in an FLSA action concerning unpaid minimum wages and overtime. The court concludes that the plaintiffs’ employment arbitration agreements cover their claims against Greensky despite its divestiture from Goldman Sachs, applying Georgia contract and agency principles. The court directs the plaintiffs to submit their claims to individual arbitration and stays the litigation.

Holdings

1. The FLSA claims fell within the broad arbitration clauses covering disputes arising out of or relating in any way to employment or association with Goldman Sachs or its affiliates.
2. Goldman Sachs's divestiture of Greensky did not terminate or invalidate the arbitration agreements.
3. Greensky was bound by the arbitration agreements under agency principles.
4. Alternatively, Greensky was an intended third-party beneficiary of the employment arbitration agreements.
5. No external legal constraint foreclosed arbitration because Plaintiffs did not establish unconscionability, fraud, duress, or a statutory prohibition against arbitration of their FLSA claims.

Questions Presented

1. Whether the parties agreed to arbitrate Plaintiffs' FLSA claims.
2. Whether Goldman Sachs's divestiture of Greensky terminated or otherwise invalidated the employment arbitration agreements.
3. Whether Greensky, a nonsignatory to the agreements, was bound under agency or third-party-beneficiary principles.
4. Whether any external legal constraint, including unconscionability, fraud, duress, or a statutory prohibition, foreclosed arbitration.

Disposition

other