Avery v. TEKsystems, Inc.

District Court, N.D. California·Decided August 21, 2024·No. 3:22-cv-02733·Unknown

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 BO AVERY, et al., Case No. 3:22-cv-02733-JSC

8 Plaintiffs, DEFENDANT’S MOTION TO 9 v. COMPEL ARBITRATION

10 TEKSYSTEMS, INC., Re: Dkt. No. 105 Defendant. 11

12 13 A class of Recruiters for TEKsystems, Inc. (“TEK”) allege TEK improperly classifies 14 Plaintiffs and other Recruiters as exempt from California overtime, wage, and hour laws and 15 therefore illegally underpays Recruiters. Now pending before the Court is Defendant’s motion to 16 compel arbitration (Dkt. No. 105).1 Having carefully considered the briefing, and with the benefit 17 of oral argument on August 15, 2024, the Court DENIES Defendant’s motion to compel 18 arbitration. TEK’s imposition of the arbitration agreement after class certification was fully 19 briefed was misleading and interfered with the Recruiters’ rights. Further, TEK waived any right 20 to arbitration of the claims of certified class members by litigating this action for two years before 21 filing the motion to compel arbitration. 22 MOTION TO COMPEL ARBITRATION 23 I. PROCEDURAL BACKGROUND 24 On April 9, 2021, a group of TEK recruiters filed a complaint in the Western District of 25 Pennsylvania, Thomas, et al. v. TEKsystems, Inc., Case No. 2:21-cv-00460-WSS (W.D. Pa.). 26 (Dkt. No. 21 at 6.) 27 1 Named Plaintiffs in this case filed a putative class action in state court on January 28, 2 2022. (Dkt. No. 1-1 at 3.) TEK removed the case to federal court on May 6, 2022. (Dkt. No. 1.) 3 TEK filed a motion to dismiss on July 28, 2022, arguing this case should be transferred, 4 dismissed, or stayed pursuant to the “first-to-file” rule. (Dkt. No. 21.) The Court denied 5 Defendant’s motion on August 31, 2022. (Dkt. No. 31.) Discovery proceeded and the Court set a 6 schedule through class certification. (Dkt. No. 37.) The Court referred the parties to the Northern 7 District of California ADR Program and a mediation, facilitated by a volunteer mediator, occurred 8 in May 2023. The parties subsequently stipulated to extend the class certification briefing 9 schedule. (Dkt. No. 54.) 10 On October 6, 2023, Plaintiffs filed a motion to certify the class. (Dkt. No. 63.) Class 11 certification briefing closed on December 14, 2023. Eight days later Plaintiffs filed an emergency 12 motion for a protective order. (Dkt. No. 73.) Plaintiffs reported “on December 19, 2023, TEK’s 13 counsel emailed Plaintiffs’ counsel to inform them that TEK had adopted an arbitration policy for 14 its internal employees, including Recruiters, and that it had disseminated notice of the policy that 15 same day.” (Id. at 7.) Plaintiffs urged the Court to void TEK’s arbitration agreement with 16 Recruiters because it was “misleading and coercive.” (Id. at 12.) The Court granted in part and 17 denied in part that motion, explaining “the determination of whether any arbitration agreement 18 [wa]s invalid [wa]s not yet ripe,” but the Court ordered TEK “to disclose any communications 19 from TEK to putative class members about their claims in this case to Plaintiffs’ counsel.” (Dkt. 20 No. 79.) 21 The Court heard argument on Plaintiffs’ class certification motion on February 1, 2024. At 22 no time during the class certification proceedings did TEK raise an arbitration agreement as an 23 issue. On February 13, 2024, the Court granted Plaintiffs’ motion and certified a “class of all 24 current and former Recruiters employed by TEK from January 28, 2018 to the final date of 25 judgment and a subclass of all the class members who worked for TEK on or after January 28, 26 2019 and are no longer employed by TEK and have not been employed by TEK for more than 72 27 hours.” (Dkt. No. 84 at 1.) 1 Plaintiffs’ opposed motion for approval of class notice. The Court ordered the parties to meet and 2 confer and submit further proposed notice, and subsequently approved class notice. (Dkt. Nos. 91, 3 97.) Pursuant to a schedule imposed by the Court, Plaintiffs moved for partial summary judgment 4 on May 14, 2024. (Dkt. No. 100.) 5 On June 10, 2024, more than two years after TEK removed this action to this Court, TEK 6 moved to compel arbitration of the claims of certain certified class members. (Dkt. No. 105.) 7 II. FACTUAL BACKGROUND 8 “A significant part of TEK’s business is placing employees,” which it calls “consultants,” 9 “on temporary assignment to TEK’s clients and hiring consultants to perform IT services for 10 clients.” (Dkt. No. 105-1 ¶ 7.) TEK’s current policy—which has been in effect since before April 11 of 2021—is that “every U.S. consultant must sign a mutual arbitration agreement with” TEK “as a 12 condition of employment before they may begin an assignment at TEK.” (Id. ¶ 8.) 13 DeAndrei Drummond, TEK’s Vice President and General Counsel, has “been a proponent 14 of expanding TEK’s arbitration policy to TEK’s internal employees” since he was hired by TEK 15 in October of 2021. (Dkt. No. 105-1 ¶¶ 4, 9.) “In mid-2023,” Mr. Drummond “sought approval 16 from business leaders at TEK to roll out an arbitration policy that would apply to all internal 17 employees of TEK in the United States.” (Id. ¶ 10.) He “received approval of that concept in late 18 September 2023.” (Id.) “The template for TEK’s Mutual Arbitration Agreement for internal 19 employees is the agreement that TEK ha[d] been using for its consultants for many years with just 20 a few minor changes.” (Id. ¶ 11.) 21 TEK “reviews and updates its policies on an annual basis, with announcements at the end 22 of the year of policies that will be changing in the upcoming year.” (Id. ¶ 12.) The arbitration 23 agreement was emailed “to all current internal employees in California,” a group of about 370 24 people, fewer than 200 of whom were potential class members, “on December 19, 2023.” (Id. ¶ 25 14.) Those internal employees “received an email sent from the email address ‘TEKsystems via 26 DocuSign’ with the subject line ‘Mutual Arbitration Agreement.’” (Id. ¶ 16.) The text of the 27 email provided: of year we typically review and update our company policies, 1 required trainings and employee information.

2 In 2024, TEKsystems is instituting a mutual arbitration agreement for internal employees in the U.S. Mutual arbitration agreements are 3 commonplace today. Most people have signed them as part of cell phone contracts, rental agreements, and credit card agreements. They 4 are increasingly common with employers as they provide a mutually agreeable way to settle disputes while being more efficient and cost 5 effective for both employees and the company.

6 We value each employee and believe that workplace concerns are best resolved through open and candid discussions, and employees are 7 encouraged to raise and discuss any concerns as soon as they arise. In the event the issue or concern cannot be resolved satisfactorily, or if 8 an employee chooses not to pursue these informal channels, employees will be required to pursue covered claims through 9 mandatory arbitration as described in the attached Agreement.

10 Attached is the Company’s Mutual Arbitration Agreement (the ‘Agreement’). Please review it carefully as it affects our mutual right 11 to litigate certain types of legal claims in court, and also includes a waiver of class and collective action claims. Under the Agreement, 12 both employees and the Company would pursue any ‘covered claims’ through individual arbitration instead of court litigation or 13 class/collective actions. In our experience, litigation in court -- particularly class and collective actions -- are wasteful, inefficient 14 means for resolving disputes, and tend to enrich only attorneys rather than the individuals who may have legitimate claims. 15 As part of this Agreement, the Company will pay for the costs of 16 arbitration, minus a small ‘filing fee.’ For pursuing individual claims, the arbitration forum is similar to court, but less formal.

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Avery v. TEKsystems, Inc., (N.D. Cal. 2024).

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