Delfingen US-Texas, LP v. Guadalupe Valenzuela

Procedural entryThis page is a short order in Delfingen US-Texas, LP v. Guadalupe Valenzuela. Read the opinion of the Court — 2013 Tex. App. LEXIS 1120
Court of Appeals of Texas·Decided February 6, 2013·No. 08-12-00022-CV·Published

Opinion

                                                           COURT OF APPEALS

                                                   EIGHTH DISTRICT OF TEXAS

                                                              EL PASO, TEXAS

DELFINGEN US-TEXAS, L.P.,

                                    Appellant,

v.

GUADALUPE VALENZUELA,

                                    Appellee.

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                  No. 08-12-00022-CV

                         Appeal from

County Court at Law No. 3

of El Paso County, Texas

(TC # 2011-251)

O P I N I O N

Delfingen US-Texas, L.P. has brought this accelerated appeal from an order denying its motion to compel arbitration.  For the reasons that follow, we affirm.

FACTUAL SUMMARY

Delfingen specializes in the design and manufacture of wiring harnesses and other plastic components for the automotive industry.  Guadalupe Valenzuela worked as a temporary employee for Delfingen for about four months in El Paso, Texas being hired as a permanent employee on May 5, 2008.  She is unable to read English.  On May 7, 2008, Valenzuela attended an orientation session for new employees conducted by Maria Guzman, Delfingen’s human resources representative.  Guzman conducted the entire orientation session in Spanish.  At the conclusion of the meeting, Valenzuela signed several documents which were in English, including the “Dispute Resolution and Arbitration Policy and Agreement”.  By signing the Agreement, Valenzuela acknowledged she had read the document and “agree[d] to submit to final and binding arbitration any and all claims and disputes that are related in any way to my employment or the termination of my employment with Delfingen.” 

On January 24, 2011, Valenzuela filed suit against Delfingen alleging she was wrongfully terminated because she pursued workers’ compensation benefits after suffering an on-the-job injury.  Delfingen filed a motion to stay proceedings and compel arbitration based on the Agreement.  In her response, Valenzuela alleged that the Agreement is procedurally unconscionable because it was never explained to her in Spanish and she was “rushed to sign the document.”  Valenzuela’s affidavit is attached to the response and avers that:

I was hired by Delfingen U.S.-Texas, L.P. to be a vent tube assembler in May 2008.  The only language I can communicate in is Spanish.  I cannot read English.  My employer knew this and hired me for the job.  When I was hired my employer presented many forms to me for signature.  All of the forms were written in English.  I understand now that one these [sic] forms may have been the DISPUTE RESOLUTION AND ARBITRATION POLICY AND AGREEMENT.  This form was not explained to me nor was it made available to me in Spanish so I could evaluate it and make a decision to accept it or reject it.  I had no idea that I was waiving my constitutional rights to bring statutory and common-law claims against my employer in a court of law.  Delfingen U.S.-Texas, L.P. never explained to me that I was entering into such an agreement.

Maria Guzman was the person who was telling me to fill out the forms.  She told me that she was going to explain only the important parts of the paperwork.  Because I do not understand English, I was at a disadvantage while going through the paperwork, as I had no means to determine for myself what the important parts of the paperwork were.  However, I took Ms. Guzman’s word that everything important was being translated for me by her.  Ms. Guzman translated the policies of Delfingen U.S.-Texas, L.P. with regard to attendance, tardiness, and punctuality in detail.  At the end of the process of completing all of the paperwork, Ms. Guzman asked me if I had any other questions.  I asked her some more questions about the attendance policy, but I had no idea that there had been a waiver of the right to bring my employer to court in the event of a dispute.  Ms. Guzman did not mention the arbitration agreement or what it meant.  I would have definitely asked for more information about this policy had I known that it was something that I had been coerced and fraudulently induced into signing. 

I understand that this is a substantially equal version of the affidavit I gave in Spanish, and this version has been read and translated to me.[1] 

Delfingen filed a written reply to Valenzuela’s response contending that the inability to speak or read English does not invalidate the Agreement.  It also challenged Valenzuela’s assertions that Guzman did not explain the arbitration agreement to her in Spanish and that Valenzuela is unable to read English.  Delfingen supported its reply with Guzman’s affidavit:

2.  All new employees hired by Delfingen must attend a new employee orientation.  The purpose of the orientation is to provide all new employees with information about the company’s policies and procedures.  I am in charge of conducting the new employee orientation sessions which take place at Delfingen’s El Paso, Texas location.  Orientation sessions are typically conducted in groups of the employees recently hired.  Sometimes, we hire employees whose native or first language is Spanish.  I am fully bilingual, and, therefore, when I conduct the orientation sessions, I explain all of the company’s policies in both English and Spanish.  As I explain each policy, I make it a point to ask the employees whether they have any questions.

3.  Delfingen has an arbitration policy which requires both the company and the employee to resolve employment-related disputes through the arbitration process. 

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