Jane Doe v. Occidental Petroleum Corp.

CourtCourt of Appeals of Texas
DecidedAugust 29, 2024
Docket01-23-00196-CV
StatusPublished

This text of Jane Doe v. Occidental Petroleum Corp. (Jane Doe v. Occidental Petroleum Corp.) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jane Doe v. Occidental Petroleum Corp., (Tex. Ct. App. 2024).

Opinion

Opinion issued August 29, 2024

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-23-00196-CV ——————————— JANE DOE, Appellant V. OCCIDENTAL PETROLEUM CORP., Appellee

On Appeal from the 270th District Court Harris County, Texas Trial Court Case No. 2019-79468

MEMORANDUM OPINION

Appellant Jane Doe was an employee of appellee Occidental Petroleum

Corporation (Oxy). Doe alleged that she was sexually assaulted by another Oxy

employee. Oxy investigated and terminated the other employee, and Doe and Oxy

entered into a Settlement Agreement in which Oxy agreed to make certain payments and agreed “not to take any adverse employment action against [Doe]

arising from the [assault].” The Settlement Agreement contained a forum selection

clause providing for resolution of “any action or proceeding arising in connection

with” the Settlement Agreement in the state or federal courts of Harris County.

After execution of the Settlement Agreement, while Doe was still employed at

Oxy, Oxy issued two stock grants to Doe, and she accepted them. The terms and

conditions of the grants contained a broad arbitration provision, including an

express provision that controversies about the arbitrability of any dispute “shall be

decided by the arbitrator.”

Doe resigned and then sued Oxy, asserting that Oxy breached the Settlement

Agreement by taking various “adverse employment actions” against her and by

failing to pay for certain medical expenses. The trial court compelled the case to

arbitration based on Oxy’s contention that Doe’s claims fell within the scope of the

arbitration agreement in the stock grants. The arbitrator determined that the claims

were arbitrable and found in favor of Oxy. Doe moved to vacate the arbitration

award on the basis that the parties had no valid arbitration agreement, but the trial

court denied that motion and rendered final judgment confirming the arbitration

determination. In her sole issue on appeal, Doe asserts that the trial court erred in

referring the claims to arbitration because the Settlement Agreement’s mandatory

forum selection clause controlled the dispute.

2 Because we conclude that a valid arbitration agreement existed between the

parties, including an express agreement that controversies regarding arbitrability

would be submitted to the arbitrator, we conclude that the trial court did not err in

referring the matter to arbitration and confirming the arbitrator’s determination.

We affirm.

Background

Doe was employed by Oxy in 2015 when she alleged that she was sexually

assaulted by another Oxy employee. The employee was criminally indicted for the

assault, and Doe sued Oxy, alleging that the employee had assaulted other female

employees and that Oxy “operated a workplace that facilitated a sexual predator’s

ability to systematically sexually abuse younger, female subordinates.” Oxy

investigated the allegations and terminated the man who assaulted Doe, but it

denied any liability in connection with the assault.

Doe and Oxy eventually entered into a settlement agreement, executed in

December 2015 (Settlement Agreement). Oxy agreed (1) to pay Doe $45,000 “to

cover attorney’s fees and expenses related to this issue”; (2) “not to take any

adverse employment action against [Doe] arising from the [assault and her

subsequent lawsuit] or this Agreement”; and (3) to “reimburse [Doe] for any

payments made, including co-payments and deductible payments, that are incurred

in the next (24) twenty-four months from the effective date of this Agreement” for

3 treatment arising from the assault “[t]o the extent any treatment is not covered by

the [Oxy-sponsored] benefit plans.” In exchange, Doe agreed to release all claims

against Oxy. The Settlement Agreement further contained a forum selection clause:

The Parties acknowledge and agree that any action or proceeding arising in connection with this Agreement shall be tried and litigated exclusively in the state and federal courts located in the County of Harris, State of Texas. The aforementioned choice of venue is intended by the parties to be mandatory and not permissive in nature, thereby precluding the possibility of litigation between the Parties with respect to or arising out of this Agreement in any jurisdiction other than those specified in this paragraph.

Doe continued to work for Oxy. In 2016, Oxy made two grants of restricted

stock units to Doe as part of its long-term incentive plan, one issued in February

2016 and a second in July 2016. The stock grants were accomplished via a “Notice

of Grant of Restrict Stock Unit Incentive Award” document and attachments that

set out the terms and conditions of the transaction (Award Agreement). The Award

Agreement provided that, by accepting the award, Doe agreed to be bound by the

attached terms and conditions, which contained the following arbitration

provision:1

(a) Any dispute arising out of or in any way related to the Grantee’s employment with the Company, or the termination of that employment, will be decided exclusively by final and binding arbitration pursuant to any procedures required by applicable law. To the extent not inconsistent with applicable law, any arbitration will be

1 The arbitration provision appears in bolded all-caps in the terms and conditions, but we have reproduced the language in here traditional type-setting for ease of readability. 4 submitted to [the] American Arbitration Association (“AAA”) and subject to AAA employment arbitration rules and mediation procedures in effect at the time of filing of the demand for arbitration. Only the following claims are excluded from this section 21: (i) claims for workers’ compensation, unemployment compensation, or state disability benefits, and claims based upon any pension or welfare benefit plan the terms of which contain an arbitration or other non-judicial dispute resolution procedure, (ii) to the extent permitted by applicable law, claims for provisional remedies to maintain the status quo pending the outcome of arbitration, (iii) claims based on compensation award agreements and incentive plans, and (iv) claims which are not permitted by applicable law to be subject to a binding pre-dispute arbitration agreement.

(b) Any controversy regarding whether a particular dispute is subject to arbitration under this section 21 shall be decided by the arbitrator.

The Award Agreement also contained a provision addressing potential

inconsistencies between the terms of the Award Agreement itself and other

agreements:

12. Entire Agreement; Relation to Plan; Interpretation. Except as specifically provided in this Section 12, the Award Agreement (including these Terms and Conditions, the Notice of Grant and all incorporated attachments and exhibits) constitutes the entire agreement between the Company and the Grantee with respect to the Award. The Award Agreement is subject to the terms and conditions of the Plan. In the event of any inconsistent provisions between the Award Agreement and the Plan, the provisions of the Plan control. References to Sections and Attachments are to Sections of, and Attachments incorporated in, the Award Agreement unless otherwise noted. In the event of any inconsistent provisions between the Award Agreement and any employment agreement between the Grantee and the Company, the provisions of the Award Agreement control, except with respect to [arbitration provision] below.

5 Accepting these stock grants required that Doe electronically sign the Award

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