Derrick Justin Mitchell v. Trans Papa Logistics, et al.

CourtDistrict Court, N.D. Texas
DecidedOctober 1, 2025
Docket4:25-cv-00453
StatusUnknown

This text of Derrick Justin Mitchell v. Trans Papa Logistics, et al. (Derrick Justin Mitchell v. Trans Papa Logistics, et al.) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Derrick Justin Mitchell v. Trans Papa Logistics, et al., (N.D. Tex. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS FORT WORTH DIVISION

DERRICK JUSTIN MITCHELL, § § Plaintiff, § § v. § Civil Action No. 4:25-cv-00453-O-BP § TRANS PAPA LOGISTICS, et al., § § Defendants. §

FINDINGS, CONCLUSIONS, AND RECOMMENDATION OF THE UNITED STATES MAGISTRATE JUDGE

Before the Court are the Motion to Compel Arbitration (ECF No. 11) and Appendix in Support (ECF No. 12) that Defendants Trans Papa Logistics, Inc., P J Food Service, Inc., and Papa John’s International, Inc. (collectively “Defendants”) filed on August 6, 2025. On August 7, 2025, the Court reminded Plaintiff Derrick Mitchell (“Mitchell”) to file a response on or before August 27, 2025. See ECF No. 14. He did not do so. Based upon a full review of the relevant pleadings and applicable legal authorities, the undersigned RECOMMENDS that Chief United States District Judge Reed O’Connor GRANT Defendants’ Motion to Compel Arbitration (ECF No. 11) and STAY the case pending completion of arbitration. I. BACKGROUND Mitchell brought this action against the Defendants alleging violations of Title I of the Americans with Disabilities Act (“ADA”). ECF No. 1. Mitchell claims that he has a qualified disability under the ADA as he suffers from paruresis. Id. at 8. He asserts that this condition qualifies as a disability under the ADA because it substantially limits a major life function. Id. He further claims that this disability prevented him from being able to participate in urine drug screens at the screening test site that Defendants required for his employment. Id. at 10. He alleges that the Defendants discriminated against him because of the disability, failed to make reasonable accommodations in the form of an alternate form of drug testing, and then fired him as a result. Id. at 9.

In the pending Motion, Defendants contend that the case is subject to binding arbitration. ECF No. 11 at 2. They assert that Mitchell electronically signed an arbitration agreement prior to commencing his employment that is valid and covers his claims. Id. at 2-5. They allege that Mitchell agreed to and acknowledged the Defendants’ “E-Signature Disclosures & Consent form” at the same time, which stated that electronic signatures were the equivalent of handwritten signatures and had the same binding effect. Id. at 2-3. The arbitration agreement provides in a paragraph that includes Mitchell’s electronic signature the following language: You and Papa John's* (collectively, the "Parties") . . . recognize that differences may arise between the Parties that cannot be resolved without the assistance of an outside party. The Parties agree to resolve any and all claims, disputes or controversies arising out of or relating to your employment with Papa John's ("Covered Claims"), exclusively by final and binding arbitration to be administered by a neutral dispute resolution agency agreed upon by the Parties at the time of the dispute. This includes claims relating to, if applicable, termination from employment with Papa John's. You and Papa John's agree that this Arbitration Agreement (this "Agreement") shall be enforceable pursuant to and interpreted in accordance with the provisions of the Federal Arbitration Act ("FAA") and that the Parties are subject to the FAA. This Agreement is a binding contract between you and Papa John's, and, except as provided below, you and Papa John's voluntarily waive any right to a trial in court before a judge or jury on any claims between you and Papa John's. ECF No. 12 at 7. The Defendants seek an order staying Mitchell’s lawsuit and referring the case to arbitration. ECF No. 11 at 8. II. ANALYSIS A. A valid agreement to arbitrate between the parties exists under Texas law.

In deciding whether the parties agreed to arbitrate, the court must apply the contract law of the state that governs the agreement. First Options v. Kaplan, 514 U.S. 938 (1995). When parties have included a forum selection clause in the contract, the court follows the selection as it “is prima facie valid and enforceable unless the opposing party shows that enforcement would be unreasonable.” Carter v. Countrywide Credit Indus., Inc., 362 F.3d 294, 299 (5th Cir. 2004) (citing Kevlin Services, Inc. v. Lexington State Bank, 46 F.3d 13, 15 (5th Cir.1995)) (explaining that although the contract in Kelvin Services did not contain an arbitration agreement, the same burden on the objecting party applies in the arbitration context). Here, the arbitration agreement does not contain a choice of law provision. ECF No. 12 at 7-10. Defendants apply Texas law in their filings to argue that the agreement is valid. ECF No. 11 at 5. Mitchell did not object to the application of Texas law and did not argue that any other state law is applicable as he did not file a response. In the absence of a dispute between the parties over

choice of law, the Court applies Texas law to determine the agreement’s enforceability. “Under Texas law, a valid contract requires an offer, acceptance, mutual assent, execution and delivery of the contract with the intent that it be mutual and binding, and consideration.” In re Online Travel Co., 953 F. Supp. 2d. 713, 718 (N.D. Tex. 2013) (collecting Texas cases). “[A] written arbitration agreement is prima facie valid and must be enforced unless the opposing party . . . alleges and proves that the arbitration clause itself was a product of fraud, coercion, or such grounds as exist at law or in equity for the revocation of the contract.” Freudensprung v. Offshore Tech. Servs., Inc., 379 F.3d 327, 341 (5th Cir. 2004) (internal quotation marks and citations omitted). Mitchell raises no such allegations here. He did not respond to the Defendants’ Motion and has not offered any facts or arguments showing that the arbitration agreement was the product of fraud, coercion, or other grounds that would invalidate it. Accordingly, the Court should find that a valid agreement to arbitrate exists between the parties under Texas law.

B. Mitchell’s claims are within the scope of the arbitration agreement. Having found that a valid agreement to arbitrate exists, the Court must next determine whether the present dispute is within the scope of the agreement. Tittle v. Enron Corp., 463 F.3d 410, 418-19 (5th Cir. 2006). “[A]rbitration is a matter of contract and a party cannot be required to submit to arbitration any dispute which he has not agreed to submit.” Id. at 418 (citing AT & T Techs., Inc. v. Commc’ns Workers of Am., 475 U.S. 643, 648, (1986)). “[In] the absence of any express provision excluding a particular grievance from arbitration, . . . only the most forceful evidence of a purpose to exclude the claim from arbitration can prevail.” AT & T Techs., 475 U.S. at 650 (citing Steelworkers v. Warrior & Gulf Navigation Co., 363 U.S. 574, 584-85 (1960)). Under the agreement at issue, claims “arising out of or relating to” Mitchell’s employment

including “termination” and alleged “discrimination or harassment on the basis of . . . disability” are subject to arbitration. ECF No. 12 at 7-8. Mitchell’s claims fall squarely within the provisions of the agreement and must be submitted to binding arbitration. C.

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Related

Kevlin Services, Inc. v. Lexington State Bank
46 F.3d 13 (Fifth Circuit, 1995)
Carter v. Countrywide Credit Industries, Inc.
362 F.3d 294 (Fifth Circuit, 2004)
Freudensprung v. Offshore Technical Services, Inc.
379 F.3d 327 (Fifth Circuit, 2004)
At&T Technologies, Inc. v. Communications Workers
475 U.S. 643 (Supreme Court, 1986)
First Options of Chicago, Inc. v. Kaplan
514 U.S. 938 (Supreme Court, 1995)
Henry Schein, Inc. v. Archer & White Sales, Inc.
586 U.S. 63 (Supreme Court, 2019)
Smith v. Spizzirri
601 U.S. 472 (Supreme Court, 2024)

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Derrick Justin Mitchell v. Trans Papa Logistics, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/derrick-justin-mitchell-v-trans-papa-logistics-et-al-txnd-2025.