Gair v. Great Star Tools USA, Inc.

CourtDistrict Court, M.D. Pennsylvania
DecidedFebruary 21, 2024
Docket4:21-cv-00976
StatusUnknown

This text of Gair v. Great Star Tools USA, Inc. (Gair v. Great Star Tools USA, Inc.) is published on Counsel Stack Legal Research, covering District Court, M.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gair v. Great Star Tools USA, Inc., (M.D. Pa. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA

CANDICE GAIR and RACHEL No. 4:21-CV-00976 BERRY, on behalf of themselves and all others similarly situated, (Chief Judge Brann)

Plaintiffs,

v.

GREAT STAR TOOLS USA, INC.,

Defendant.

MEMORANDUM OPINION

FEBRUARY 21, 2024 In 2020, Shop-Vac Corporation (“Shop-Vac”) laid off most of its staff, allegedly without providing adequate legal notice. Candice Gair filed suit on behalf of herself and other Shop-Vac employees and, in 2023, sought to certify a class action against Great Star Tools USA, Inc. (“Great Star”), as the successor to Shop- Vac, for violating the Worker Adjustment and Retraining Notification Act1 (“WARN Act”). Although Great Star opposed certification largely on the ground that many of the proposed class members had signed arbitration agreements to which Gair was not subject—and she therefore was not an adequate class representative— this Court disagreed, certified the class, and further appointed Rachel Berry as a representative of a subclass of individuals who had signed arbitration agreements.2

1 29 U.S.C. § 2101, et seq. Great Star now moves to dismiss Berry from the complaint on the ground that she has signed an arbitration agreement that prohibits her from maintaining suit

against Great Star. Although there is no question that Berry signed a binding arbitration agreement, the language of that agreement makes clear that it does not apply retroactively. Because Berry’s WARN Act claim arose prior to her signing the

arbitration agreement, Great Star’s motion must be denied. I. BACKGROUND A. Procedural History In 2021, Gair, on behalf of herself on all similarly situated individuals, filed a

complaint—which was later amended—against Shop-Vac3 and Great Star, raising a single claim for a violation of the WARN Act.4 In early 2023, Gair moved to certify a class, which Great Star opposed.5 This Court certified the class after finding that Gair met all conditions for class certification.6 Although many of the proposed class

members had signed arbitration agreements, the Court found that these agreements were not an impediment to certifying Gair as the class representative because that defense was not applicable to Gair.7 Nevertheless, the Court appointed Berry, who

3 Shop-Vac Corporation (properly named as SV Wind-Down Corporation) was later dismissed from this action. Doc. 56. 4 Docs. 1, 21. 5 Docs. 47, 66. 6 Docs. 72, 73. 7 Doc. 72 at 10. has signed an arbitration agreement, as a class representative to represent a subclass of putative plaintiffs who had signed arbitration agreements with Great Star.8

Great Star thereafter filed what it terms a motion to dismiss Berry as a plaintiff in this matter.9 Great Star argues that Berry should be dismissed from the matter because she signed an arbitration agreement with Great Star and, under the Federal

Arbitration Act (“FAA”), her claim must be dismissed since she may only pursue her claim through arbitration.10 Plaintiffs respond that Berry should not be dismissed from this action for three reasons.11 First, they contend that Great Star has waived any arbitration defense by

failing to raise it earlier in the proceedings and, even if not waived, any issues surrounding the arbitration agreement must be litigated as to the class, rather than just Berry.12 Second, Plaintiffs argue that Berry signed her arbitration agreement

after her WARN Act claim arose and, because that agreement should not apply retroactively, it does not cover this claim.13 Third, Plaintiffs assert that a representative claim under the WARN Act may not be waived, even pursuant to an arbitration agreement.14

8 Id. at 10-11; Doc. 73. 9 Doc. 74. 10 Doc. 75. 11 Doc. 79. 12 Id. at 7-11. 13 Id. at 11-13. 14 Id. at 13-21. Great Star argues that none of Plaintiffs assertions are meritorious.15 This matter has now been fully briefed and is ripe for disposition. For the following

reasons, Great Star’s motion will be denied. B. Facts Gair and approximately 400 other employees of Shop-Vac were terminated

around September 15, 2020 when Shop-Vac’s Williamsport, Pennsylvania plant closed without warning.16 Those employees were terminated without notice, severance pay, or health care coverage.17 However, in late December 2020, Great Star, a subsidiary of a Chinese company named Hangzhou Great Star Industrial Co.,

LLC, acquired substantially all of Shop-Vac’s assets.18 Great Star reopened Shop-Vac’s shuttered Williamsport manufacturing plant and rehired hundreds of former Shop-Vac employees.19 As a condition of applying

for employment with Great Star, the rehired individuals were required sign a contract containing a dispute resolution policy that mandated arbitration of any and all disputes between Great Star and its applicants and employees (the “Arbitration Agreement”).20 Gair did not apply for a position with Great Star and, therefore, is

not bound by the Arbitration Agreement. It is estimated that 436 Shop-Vac

15 Doc. 81. 16 Doc. 21 ¶¶ 1-2. 17 Id. ¶ 22. 18 Id. ¶¶ 25, 26, 29, 30. 19 Id. ¶¶ 28, 32, 37. 20 Doc. 75-1 at 3. employees were terminated in September 2020, and that 206 employees were subsequently hired by Great Star and signed the Arbitration Agreement, including

Berry.21 II. LAW Although Great Star purports to bring a motion to dismiss, its motion to

compel arbitration is more properly considered a motion for partial summary judgment. The United States Court of Appeals for the Third Circuit has explained which standard is applicable when seeking to compel arbitration: when it is apparent, based on the face of a complaint, and documents relied upon in the complaint, that certain of a party’s claims are subject to an enforceable arbitration clause, a motion to compel arbitration should be considered under a Rule 12(b)(6) standard without discovery’s delay. But if the complaint and its supporting documents are unclear regarding the agreement to arbitrate, or if the plaintiff has responded to a motion to compel arbitration with additional facts sufficient to place the agreement to arbitrate in issue, then the parties should be entitled to discovery on the question of arbitrability before a court entertains further briefing on the question. After limited discovery, the court may entertain a renewed motion to compel arbitration, this time judging the motion under a summary judgment standard. In the event that summary judgment is not warranted because the party opposing arbitration can demonstrate, by means of citations to the record, that there is a genuine dispute as to the enforceability of the arbitration clause, the court may then proceed summarily to a trial regarding the making of the arbitration agreement or the failure, neglect, or refusal to perform the same, as Section 4 of the FAA envisions.22

21 Doc. 69 at 4 n.3. 22 Guidotti v. Legal Helpers Debt Resol., L.L.C., 716 F.3d 764, 776 (3d Cir. 2013) (brackets, citations, and quotation marks omitted). Here, the amended complaint does not reference or cite to the Arbitration Agreement.23 Moreover, the parties have engaged in discovery, and Great Star’s

motion relies upon extraneous materials—specifically a declaration from a Great Star human resources employee, the Arbitration Agreement, and a document signed by Berry agreeing to be bound by the Arbitration Agreement.24 Accordingly, the

Court will evaluate Great Star’s motion under the summary judgment standard. Pursuant to Federal Rule of Civil Procedure

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