Kirlew v. Golden Nugget Lake Charles L L C

CourtDistrict Court, W.D. Louisiana
DecidedJuly 28, 2022
Docket2:22-cv-00309
StatusUnknown

This text of Kirlew v. Golden Nugget Lake Charles L L C (Kirlew v. Golden Nugget Lake Charles L L C) is published on Counsel Stack Legal Research, covering District Court, W.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kirlew v. Golden Nugget Lake Charles L L C, (W.D. La. 2022).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA LAKE CHARLES DIVISION

NEIKASHAY D KIRLEW CASE NO. 2:22-CV-00309

VERSUS JUDGE JAMES D. CAIN, JR.

GOLDEN NUGGET LAKE CHARLES MAGISTRATE JUDGE KAY LLC

MEMORANDUM RULING

Before the court is a Motion to Dismiss and Compel Arbitration, alternatively, Motion to Stay [doc. 5] filed by defendant Golden Nugget Lake Charles, LLC (“Golden Nugget”). Plaintiff Neikashay Kirlew opposes the motions. Doc. 7. I. BACKGROUND

This suit arises from employment discrimination allegations made by Kirlew, a black woman whose national origin is Jamaican, against Golden Nugget, where she was employed as a beverage server from October 2016 until November 2021. Doc. 1; doc. 5, att. 2, p. 1. Kirlew filed suit in this court on January 31, 2022, raising claims under Title VII of the Civil Rights Act. Doc. 1. Golden Nugget then moved to compel arbitration and dismiss the suit or, alternatively, stay proceedings pending arbitration. Doc. 5. To this end it points out that Kirlew electronically signed a “Mutual Agreement to Arbitrate” when she began her employment, under which she is obligated to arbitrate certain claims arising from the course and scope of her employment (including those “arising under the federal and state employment laws,” which “includes, but is not limited to . . . Title VII of the Civil Rights Act”). See doc. 5, att. 2, p. 5. The agreement also provides that acts of acceptance

include either beginning or continuing work after receiving notice of the policy. Id. Golden Nugget updated this policy in 2018, providing multiple notices of the new policy to employees between that time and when Kirlew left the company. Id. at pp. 1–2, ¶¶ 7–14. The 2018 agreement covers “claims for . . . discrimination or harassment because of race, gender, color, pregnancy, religion, national origin, ancestry, age, disability, medical condition, marital status, sexual orientation, gender identity, or any other

characteristic protected by applicable law[.]” Id. at p. 8. It also provides that continued employment constitutes acceptance, even without signature. Id. at 9–10. Accordingly, Golden Nugget maintains that Kirlew is bound to arbitrate all claims raised in this suit. Doc. 5. Kirlew opposes the motion, arguing that she never received or signed either the 2016 or 2018 agreement. Doc. 7.

II. LAW & APPLICATION

On a motion to compel arbitration, the court’s first task is to determine whether the parties agreed to arbitrate the dispute. Garrett v. Circuit City Stores, Inc., 449 F.2d 672, 674 (5th Cir. 2006). To this end the court asks (1) is there a valid arbitration agreement and (2) does the dispute fall within the scope of that agreement? Sherer v. Green Tree Svcg., LLC, 548 F.3d 379, 381 (5th Cir. 2008). Step one focuses on contract formation while step two focuses on contract interpretation. Kubala v. Supreme Prod. Servs., Inc., 830 F.3d 199, 201 (5th Cir. 2016). The first step is governed by state law. Klein v. Nabors Drilling USA L.P., 710 F.3d 234, 236 (5th Cir. 2013).

Under Louisiana law, there is no requirement that a party provide written consent to an arbitration agreement. Marino v. Dillard’s, Inc., 413 F.3d 530, 532 (5th Cir. 2005). Instead, a party may bind himself to an arbitration agreement or other contract with “action or inaction . . . clearly indicative of consent,” including his continued employment. Id. (citing La. Civ. Code art. 1927). This point was emphasized in Omni Hotels Management Corporation v. Bayer, where the court found that employees were bound by an arbitration

agreement under Louisiana law through their continued employment even though they refused to sign the agreement and, in some cases, the receipt intended to provide proof of notice. 2006 WL 8456480 (E.D. La. Jan. 11, 2006); aff’d, 235 F. App’x 208, 211 (5th Cir. 2007); accord Lee v. Coca-Cola Enterps., Inc., 2008 WL 920742 (W.D. La. Mar. 4, 2008). Golden Nugget provides the electronic signature linked with Kirlew’s account in its

employee software and explains how new employees used this software and signature to execute numerous documents, including the 2016 arbitration agreement, as part of their onboarding process. Doc. 5, att. 2, pp. 1, 4. In a supplemental declaration, Golden Nugget’s human resources vice president states that this same signature was used by Kirlew to execute her electronic pay authorization form and that she could not have been paid through

direct deposit otherwise. Kirlew maintains that the electronic signature provided by Golden Nugget is not hers and provides numerous examples of her signature as attempted proof. Doc. 7, att. 2. She provides an affidavit to this effect, in which she also states that she was never given a copy of the 2018 agreement and that she never saw it in Kronos or anywhere else. Doc. 7, att. 1. She further states that she only heard about this agreement in a brief reference during

a preshift meeting from her supervisor in 2018, and then later after she filed her EEOC complaint. Id. She also provides unsworn statements from four former Golden Nugget employees, who began work between 2015 and 2018 and state that they (1) were never given an arbitration agreement to review or sign, (2) never saw one posted, and (3) never had the existence of any such agreement explained to them by management. Doc. 7, att. 3. Finally, Kirlew provides a screenshot of a Change.org petition signed by fifteen other

individuals, asserting that they were not given a “thorough detailed explanation” of the arbitration agreement and/or were not given “an electronic holding form permitting the company to use your electronic signature for the entire duration of your employment.” Doc. 7, att. 4. At the outset, the court finds that the statements from Kirlew’s fellow employees

and the petition signatures are insufficient to create issues of material fact. Namely, the petition does not provide sufficient context for the identity of the signers, does not contain any guarantees of their truthfulness in this matter, and is unclear as to whether they are asserting that they never received the policy (or notice thereof), never had it sufficiently explained to them, or both. As for the statements, these are similarly lacking in context and

do not exclude the possibility—as asserted by Golden Nugget—that notice of the 2018 policy was provided through the timekeeping software itself. The court questions the veracity of the statements by Kirlew as to her electronic signature. A litigant’s affidavit may serve to defeat a motion for summary judgment when it is based on personal knowledge and contains factual assertions sufficient to create issues of material fact, even though the affidavit is also self-serving. C.R. Pittman Constr. Co.,

Inc. v. Nat’l Fire Ins. Co. of Hartford, 453 F. App’x 439, 443 (5th Cir. 2009). Under the “sham affidavit doctrine,” the court will not “allow a party to defeat a motion for summary judgment using an affidavit that impeaches, without explanation, sworn testimony.” Seigler v. Wal-Mart Stores Tex., LLC, 30 F.4th 472, 478 (5th Cir. 2022). This doctrine is only applied, however, to inherent and unexplained inconsistencies with prior sworn testimony. Id.

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