Lee v. American Homes 4 Rent, LP

CourtDistrict Court, D. Nevada
DecidedMay 31, 2022
Docket2:21-cv-01870
StatusUnknown

This text of Lee v. American Homes 4 Rent, LP (Lee v. American Homes 4 Rent, LP) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lee v. American Homes 4 Rent, LP, (D. Nev. 2022).

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 Jaemon Lee, Case No.: 2:21-cv-01870-JAD-DJA

4 Plaintiff Order Granting Motion to Compel Arbitration of Claims against American 5 v. Homes 4 Rent, Granting in Part and Denying in Part Motion to Dismiss, 6 Denying Motions for Injunctive Relief, and American Homes 4 Rent, L.P. and Boyd Granting Motion to Lift Discovery Stay 7 Gaming Corporation, [ECF Nos. 6, 20, 29, 30, 46] 8 Defendants

9 Jaemon Lee sues his former employers, Boyd Gaming Corporation and American Homes 10 4 Rent (AH4R), alleging that AH4R fired him after Boyd breached a settlement agreement that 11 restricts what Boyd may disclose to Lee’s prospective employers by telling AH4R that Lee had 12 filed discrimination and retaliation claims against Boyd. AH4R moves to compel arbitration of 13 the claims against it based on Lee’s arbitration agreement with the company. Boyd moves to 14 dismiss most of the claims against it, arguing that some are insufficiently pled and others are 15 barred by the settlement agreement. Lee opposes these requests and moves for an expedited trial 16 and to lift the discovery stay that was entered last December. 17 Because Lee signed an arbitration agreement with AH4R, I grant the motion to compel 18 arbitration and dismiss Lee’s claims against AH4R. I also grant in part Boyd’s motion to dismiss 19 Lee’s claims for discrimination, intentional and negligent infliction of emotional distress, bad 20 faith, and interference with prospective business relations, but I do so with instructions and leave 21 to amend by June 30, 2022. Finally, I deny Lee’s request for an expedited trial but grant his 22 motion to lift the discovery stay and give Boyd and Lee until June 14, 2022, to file a stipulation 23 to reset their early-neutral-evaluation session. 1 Background1 2 Jaemon Lee is a transgender individual who identifies as male.2 He alleges that he filed 3 charges of discrimination and retaliation against Boyd with the Nevada Equal Rights 4 Commission (NERC),3 which resulted in a negotiated settlement agreement in mid-2020.4 As

5 part of that agreement, Boyd agreed that any future job references to Lee’s potential employers 6 would “be limited only to date of hire, number of wages, position held, and [the] date 7 employment ended,”5 and Boyd could “[n]ot to divulge the terms and conditions of [the 8 settlement] nor the allegations of this charge to any third party.”6 9 After he left Boyd, Lee removed the company from his LinkedIn profile on the advice of 10 a NERC employee, who was “prompted by the suspicion that Boyd . . . had been ‘disparaging’ 11 [Lee] to prospective employers since [Lee’s] charge against Boyd . . . had been resolved.”7 Lee 12 then applied for an “Enterprise Architect” position with AH4R,8 was interviewed for the 13 position, and hired on February 21, 2020.9 A few days later, one of AH4R’s recruiters asked Lee 14 if he had worked at Boyd, stating that she learned of his employment through his LinkedIn

15 profile.10 Lee “knew that [claim] was not true” because he had removed that entry from his 16

1 These facts are summarized from Lee’s complaint (ECF No. 1) and are not intended as findings 17 of fact. 18 2 ECF No. 1 at ¶ 86. 3 Id. at ¶ 66. 19 4 Id. at ¶ 67. 20 5 Id. at ¶ 68. 21 6 Id. at ¶ 69. 7 Id. at ¶ 23–24. 22 8 Id. at ¶¶ 16–18. 23 9 Id. at ¶ 20. 10 Id. at ¶ 21. 1 resume months earlier.11 But at the recruiter’s request, Lee provided her and his AH4R manager 2 Phillip Irby with the email addresses and phone numbers of Nathan Hirschi and Johan 3 Mortenson, his employers at Boyd.12 Lee was never told whether the recruiter spoke to Hirschi 4 or Mortenson.13

5 Lee started work at AH4R on March 9, 2020,14 but he was fired five days later.15 6 AH4R’s human-resources department told Lee that the company “had received complaints from 7 several people about him” but would not provide any further details.16 Lee alleges that he “had 8 no problems or other unpleasant interactions with any person” during his five-day tenure.17 He 9 believes that Hirschi told Irby that Lee “was transgender and . . . made a complaint against 10 [Boyd] for sex discrimination and retaliation.”18 Lee alleges that Hirschi and Irby were friends 11 and had previously exchanged information that led to Boyd rescinding a job offer to a 12 prospective employee while Lee was employed there.19 13 Lee filed this complaint in October 2021, alleging that Boyd’s disclosure of his 14 transgender status and NERC claims, Boyd’s conduct while Lee was employed there, and

15 AH4R’s decision to fire him violate Title VII and Nevada Revised Statute (NRS) 613.330’s 16 17

18 11 Id. at ¶¶ 22, 23–24. 12 Id. at ¶ 36. 19 13 Id. at ¶ 37. 20 14 Id. at ¶ 39. 21 15 Id. at ¶ 40. 16 Id. at ¶¶ 41–46. 22 17 Id. at ¶¶ 50–51. 23 18 Id. at ¶¶ 52, 56. 19 Id. at ¶¶ 57–65. 1 prohibition on discrimination based on sex and gender identity.20 He also brings retaliation 2 claims under federal and Nevada law against both companies. And against Boyd only, Lee 3 asserts claims for breach of his settlement agreement, breach of the covenant of good faith and 4 fair dealing, “intentional/negligent infliction of emotional distress,” and interference with

5 prospective business advantage.21 6 Discussion 7 I. AH4R’s motion to compel arbitration [ECF No. 6] 8 AH4R moves to compel arbitration and dismiss this case22 based on an arbitration 9 agreement that Lee electronically signed during his employment onboarding process.23 AH4R 10 argues that the agreement explicitly requires “claims for unlawful discrimination” on the basis of 11 “sex [and] gender identity and expression” to be arbitrated.24 It also requires the parties to 12 arbitrate “any disputes about the applicability, scope, enforceability, validity[,] or waiver of this 13 [a]greement.”25 AH4R therefore argues that the claims against it, including any questions 14 concerning the validity of the arbitration agreement, must be resolved by an arbitrator and that

15 this federal court case against it must be dismissed.26 Lee responds that the arbitration 16 agreement is unenforceable because AH4R didn’t sufficiently show that he signed the 17 18

19 20 Id. at ¶¶ 80–116. 21 Id. at ¶¶ 117–51. 20 22 ECF No. 6. AH4R filed a corrected image of this motion and its exhibits to comply with 21 Local Rule (L.R.) IA 10-3. ECF No. 62. I cite to the corrected version throughout this order. 23 ECF No. 62 at 3. 22 24 Id. at 4; ECF No. 62-6 at 2–3 (AH4R’s arbitration agreement). 23 25 ECF No. 62 at 8; ECF No. 62-6 at 3. 26 ECF No. 62. 1 agreement.27 He alternatively argues that his claims against AH4R are ”intertwined” with his 2 claims against Boyd and thus, “this matter fails squarely outside of the unenforceable arbitration 3 agreement.”28 He asks that I stay this case in its entirety if I find that his claims against AH4R 4 must be arbitrated.29

5 A. The Federal Arbitration Act (FAA) 6 The FAA states that “[a] written provision in any . . . contract evidencing a transaction 7 involving commerce to settle by arbitration a controversy” arising out of the contract or 8 transaction “shall be valid, irrevocable, and enforceable save upon grounds as exist at law or in 9 equity for the revocation of any contract.”30 It permits any party “aggrieved by the alleged 10 failure, neglect, or refusal of another to arbitrate under a written agreement for arbitration” to 11 petition any federal district court for an order compelling arbitration in the manner provided for 12 in the arbitration agreement.31 The FAA “establishes a federal policy favoring arbitration, 13 requiring that [courts] rigorously enforce agreements to arbitrate”32 and provides “that [if a] 14 contract contains an arbitration clause, there is a presumption of arbitrability.”33 “By its terms,

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Lee v. American Homes 4 Rent, LP, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lee-v-american-homes-4-rent-lp-nvd-2022.