Margulis v. HomeAdvisor, Inc.

CourtDistrict Court, E.D. Missouri
DecidedJanuary 31, 2020
Docket4:19-cv-00226
StatusUnknown

This text of Margulis v. HomeAdvisor, Inc. (Margulis v. HomeAdvisor, Inc.) is published on Counsel Stack Legal Research, covering District Court, E.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Margulis v. HomeAdvisor, Inc., (E.D. Mo. 2020).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

MARILYN MARGULIS and ) MAX MARGULIS, individually and on ) behalf of all others similarly situated, ) ) Plaintiff(s), ) Case No. 4:19-cv-00226-SRC ) vs. ) ) HOMEADVISOR, INC., and JOHN ) DOES 1-10, ) ) Defendant(s). )

MEMORANDUM AND ORDER This matter comes before the Court on Defendant HomeAdvisor, Inc.’s Motion to Compel Individual Arbitration and Enforce Class Action Waiver [30]. Plaintiffs oppose the Motion. For the reasons set forth below, the Court DENIES the Motion, without prejudice. I. BACKGROUND This case involves claims under the Telephone Consumer Protection Act, 47 U.S.C. § 227 (TCPA) and Missouri’s No-Call Law, Mo. Rev. Stat. § 407.1098. Plaintiffs Max and Marilyn Margulis allege that they received multiple unsolicited telemarketing calls from Defendant HomeAdvisor, Inc. or unidentified individuals acting on HomeAdvisor’s behalf. After HomeAdvisor removed this case to federal court, Plaintiffs amended their Complaint to add class action allegations. HomeAdvisor subsequently filed the present Motion to Compel Individual Arbitration and Enforce Class Action Waiver. HomeAdvisor asserts that Plaintiffs consented to arbitrate this dispute with HomeAdvisor and agreed not to commence or maintain any class action against HomeAdvisor. Plaintiffs contend that they did not enter into contracts with HomeAdvisor and therefore no such arbitration agreement or class action waiver exists. Plaintiffs also request oral argument on HomeAdvisor’s Motion. II. STANDARD “Arbitration agreements are governed by the Federal Arbitration Act (“FAA”).” Hoffman

v. Cargill Inc., 236 F.3d 458, 461 (8th Cir. 2001). The FAA provides that: A party aggrieved by the alleged failure, neglect, or refusal of another to arbitrate under a written agreement for arbitration may petition any United States district court which, save for such agreement, would have jurisdiction under title 28, in a civil action or in admiralty of the subject matter of a suit arising out of the controversy between the parties, for an order directing that such arbitration proceed in the manner provided for in such agreement.

9 U.S.C. § 4. There is a “liberal federal policy favoring arbitration.” AT&T Mobility LLC v. Concepcion, 563 U.S. 333, 339 (2011). Accordingly, “courts must place arbitration agreements on an equal footing with other contracts” and enforce them according to their terms. Id. However, “[a] matter should not be sent to arbitration unless there is a valid agreement to arbitrate and the underlying dispute falls within the scope of that agreement.” Northport Health Servs. of Arkansas, LLC v. Posey, 930 F.3d 1027, 1030 (8th Cir. 2019) (quoting Telectronics Pacing Sys., Inc. v. Guidant Corp., 143 F.3d 428, 433 (8th Cir. 1998)). “While ‘any doubts concerning the scope of arbitrable issues should be resolved in favor of arbitration[,] … a party who has not agreed to arbitrate a dispute cannot be forced to do so.’” Id. (quoting Lyster v. Ryan's Family Steak Houses, Inc., 239 F.3d 943, 945 (8th Cir. 2001)). III. DISCUSSION HomeAdvisor moves to compel arbitration because—according to HomeAdvisor— Plaintiffs used HomeAdvisor’s website and thereby agreed to HomeAdvisor’s Terms and Conditions, which include an agreement to arbitrate. Plaintiffs dispute that they ever consented to the Terms and Conditions or otherwise agreed to arbitration. Thus, the threshold question this Court must address is whether the Parties entered into a valid arbitration agreement. Nebraska Mach. Co. v. Cargotec Sols., LLC, 762 F.3d 737, 741 n.2 (8th Cir. 2014). A. Motion to Compel Arbitration The Eighth Circuit has instructed District Courts to analyze a motion to compel

arbitration “under a standard akin to [a motion for] summary judgment.” Nebraska Mach. Co., 762 F.3d at 741. Accordingly, the Court must view the evidence in the light most favorable to the non-moving party, resolving all factual disputes in their favor. Id. at 743. The Court may not compel arbitration where any genuine issue of material fact remains as to whether a valid arbitration agreement exists. Id. Applying this standard to the present Motion, the Court finds that HomeAdvisor has failed to demonstrate the absence of any genuine issue of material fact. HomeAdvisor has offered uncontroverted evidence that accounts were created on the HomeAdvisor.com website in the names of Marilyn and Max Margulis. Doc. 31-1 at ¶ 5; Doc. 51-1 at ¶ 4. HomeAdvisor has also submitted evidence showing that the person or persons who created the HomeAdvisor.com

account in the name of Max Margulis accessed the website from the IP address 99.28.88.33. Doc. 51-1 at ¶¶ 4-6. Finally, HomeAdvisor has offered evidence that IP address 99.28.88.33 corresponds to an address in Chesterfield, Missouri with a ZIP code of 63017. Id. at at ¶¶ 7-10. But HomeAdvisor has not offered any evidence specifically linking the Plaintiffs to IP address 99.28.88.33. In the summary judgment context, “[w]here the supporting evidentiary matter of the moving party reveals ‘unexplained gaps' or where the truth is not certain, the movant has not sustained the burden of demonstrating the absence of genuine issue of fact.” Giordano v. Lee, 434 F.2d 1227, 1231 (8th Cir. 1970). Here, HomeAdvisor has failed to connect Plaintiffs to the IP address at issue. This “unexplained gap” in HomeAdvisor’s proffered evidence leaves a genuine issue of fact as to whether Plaintiffs created the HomeAdvisor.com accounts and thereby agreed to the Terms and Conditions. Because at least one genuine issue of material fact remains,1 the Court must deny HomeAdvisor’s Motion to Compel Arbitration.

B. Summary Trial of Disputed Factual Issues The FAA provides for a summary-trial procedure where the existence of an arbitration agreement is factually disputed: The court shall hear the parties, and upon being satisfied that the making of the agreement for arbitration or the failure to comply therewith is not in issue, the court shall make an order directing the parties to proceed to arbitration in accordance with the terms of the agreement. … If the making of the arbitration agreement or the failure, neglect, or refusal to perform the same be in issue, the court shall proceed summarily to the trial thereof. If no jury trial be demanded by the party alleged to be in default, or if the matter in dispute is within admiralty jurisdiction, the court shall hear and determine such issue. Where such an issue is raised, the party alleged to be in default may, except in cases of admiralty, on or before the return day of the notice of application, demand a jury trial of such issue, and upon such demand the court shall make an order referring the issue or issues to a jury in the manner provided by the Federal Rules of Civil Procedure, or may specially call a jury for that purpose. 9 U.S.C. § 4 (emphasis added).

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Margulis v. HomeAdvisor, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/margulis-v-homeadvisor-inc-moed-2020.