MVT Services LLC and Juan Garcia v. Erika Robles Individually, as Representative of the Estate of Orlando Robles, and as Next Friend of K.R., Maria Castillo, Elainna Robles, Athena Schmidt, Melina Robles, Byanca Santos and Paulina Merino on Behalf of Minor Child O.R.R.

CourtCourt of Appeals of Texas
DecidedJune 17, 2024
Docket08-23-00181-CV
StatusPublished

This text of MVT Services LLC and Juan Garcia v. Erika Robles Individually, as Representative of the Estate of Orlando Robles, and as Next Friend of K.R., Maria Castillo, Elainna Robles, Athena Schmidt, Melina Robles, Byanca Santos and Paulina Merino on Behalf of Minor Child O.R.R. (MVT Services LLC and Juan Garcia v. Erika Robles Individually, as Representative of the Estate of Orlando Robles, and as Next Friend of K.R., Maria Castillo, Elainna Robles, Athena Schmidt, Melina Robles, Byanca Santos and Paulina Merino on Behalf of Minor Child O.R.R.) 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.

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MVT Services LLC and Juan Garcia v. Erika Robles Individually, as Representative of the Estate of Orlando Robles, and as Next Friend of K.R., Maria Castillo, Elainna Robles, Athena Schmidt, Melina Robles, Byanca Santos and Paulina Merino on Behalf of Minor Child O.R.R., (Tex. Ct. App. 2024).

Opinion

COURT OF APPEALS EIGHTH DISTRICT OF TEXAS EL PASO, TEXAS

MVT SERVICES, LLC, and JUAN GARCIA, § No. 08-23-00181-CV

Appellants, § Appeal from

v. § 448th Judicial District Court

ERIKA ROBLES, INDIVIDUALLY, AS § of El Paso County, Texas REPRESENTATIVE OF THE ESTATE OF ORLANDO ROBLES, and AS NEXT § (TC# 2022DCV3059) FRIEND OF K.R.; MARIA CASTILLO; ELAINNA ROBLES; ATHENA SCHMIDT; § MELINA ROBLES; BYANCA SANTOS; and PAULINA MERINO ON BEHALF OF § O.R.R., § Appellees.

MEMORANDUM OPINION

Orlando Robles and Appellant Juan Garcia were hired by OEP Holdings, LLC (OEP),

which leased their services to Appellant MVT Services, LLC (MVT) to perform work as truck

drivers. Following a collision that led to Orlando’s 1 death, his estate and various family members

(collectively, the Robles Family) sued Garcia and MVT (collectively, the MVT Appellants) for

wrongful death. The MVT Appellants moved to compel arbitration based on OEP’s arbitration

agreement they contend Orlando signed and they can enforce. The trial court denied the motion,

1 Because many of the Appellees share the same last name, we use Orlando’s first name for clarity. and the MVT Appellants appealed. Because we find that the MVT Appellants did not establish

their right to adopt the Plan, we affirm the trial court’s judgment.

FACTUAL AND PROCEDURAL BACKGROUND

On October 28, 2020, Garcia was driving an 18-wheeler tractor trailer on an interstate

highway near Roland, Oklahoma, when he collided with a stopped truck. Orlando was in the

sleeper berth at the time and sustained significant injuries, which led to his death.

A. The Robles Family’s lawsuits

After Orlando’s death, the Robles Family sued several defendants, including MVT and

Garcia, in an Oklahoma state court, where litigation ensued for approximately two years. After

settling with the other defendants, the Robles Family dismissed its claims against the MVT

Appellants without prejudice. Then in October 2022, the Robles Family brought a wrongful death

action against the MVT Appellants in El Paso, where Garcia resided. The Robles Family alleged

Orlando’s death was caused by Garcia’s negligence; MVT was liable for Garcia’s negligence

based on a respondent superior theory of liability; and MVT was negligent in hiring Garcia. The

same month, the MVT Appellants filed a joint answer to the petition, denying the Robles Family’s

claim and raising, inter alia, the affirmative defense of arbitration. They argued Orlando had

agreed to resolve “all workplace injury and negligence disputes” through binding arbitration,

which agreement was binding on his heirs.

(1) The MVT Appellants’ motion to compel arbitration

In May 2023, the MVT Appellants filed a joint motion to stay proceedings and compel

arbitration (motion to compel arbitration), alleging that when Orlando was first hired by OEP, he

signed an agreement to arbitrate contained in OEP’s Occupational Injury Benefit Plan (the Plan),

whereby he agreed to arbitrate all personal injury and wrongful death claims arising from his

2 employment. They alleged MVT had adopted the Plan, giving it the right to enforce the agreement

against the Robles Family as Orlando’s beneficiaries. The MVT Appellants did not provide a

separate analysis in their motion regarding Garcia’s right to enforce the agreement.

(2) The arbitration documents

In their motion, the MVT Appellants attached an affidavit from OEP’s Director of Human

Resources, John Gregory Ginger, wherein he averred that in lieu of subscribing to the Texas

Workers’ Compensation System, OEP provides self-funded workplace injury benefits to its

employees through its Occupational Injury Benefit Plan. Ginger explained that OEP’s Plan offers

its employees two coverage options: Tier 2 benefits, which offer a base amount of benefits but are

not subject to an arbitration agreement; and Tier 1 benefits, which offer an increased benefit

amount in exchange for an agreement to arbitrate certain claims. According to Ginger, when

Orlando was hired by OEP, he chose Tier 1 benefits and signed two documents reflecting his

agreement to arbitrate workplace injury or negligence claims.

(a) The SPD and SPD acknowledgment

Ginger attached to his affidavit the “Injury Benefit Plan and Summary Plan Description

Acknowledgement” (the SPD Acknowledgment). It purportedly contained Orlando’s electronic

signature, stating he had been given instructions on how to log into his “paperwork account” to

view the “Summary Plan Description (SPD) of the Occupational Injury Benefit Plan of OEP

HOLDING, LLC.,” and he had reviewed and understood the provisions of the Plan. 2 Ginger also

2 In a supplemental affidavit, Ginger provided a detailed description of OEP’s security features used to obtain Orlando’s electronic signature, in accordance with the Texas Uniform Electronic Transaction Act. See Tex. Bus. & Com. Code Ann. § 322.009. The Robles Family did not challenge the efficacy of those security features and therefore did not rebut the presumption that Orlando’s electronic signature on the documents was genuine. See Solcius, LLC v. Meraz, No. 08-22-00146-CV, 2023 WL 2261414, at *4–5 (Tex. App.—El Paso Feb. 27, 2023, no pet.) (mem. op.) (finding electronic signature on contract was genuine where party disputing its validity did not challenge the security features used to obtain it) (citing Aerotek, Inc. v. Boyd, 624 S.W.3d 199, 204 (Tex. 2021)).

3 attached to his affidavit a copy of the SPD, which described two tiers of coverage and provided

that participants electing to receive Tier 1 benefits (Tier 1 Participants) agree to resolve any

disputes regarding “covered claims,” including workplace injuries, under the terms of the

arbitration agreement set forth therein. 3 The SPD contained several provisions relating to

arbitration, including “Arbitration is the Exclusive Remedy for Covered Claims,” which provides:

Covered Claims shall be exclusively resolved by binding arbitration. While both Tier 1 Participants and Company retain all substantive legal rights and remedies under this Agreement, Tier 1 Participants and Company are both waiving all rights which either may have with regard to trial, whether jury or non-jury, in state or federal court for any Covered Claim.

The SPD defines “covered claims” as “any personal injury suffered by Tier 1 Participants

while in the Course and Scope of their employment with Company, including but not limited to,

claims for negligence, gross negligence, physical impairment, disfigurement, pain and suffering,

mental anguish, wrongful death [and] survival actions” and any expenses and damages “arising

out of or related to personal any injury.” The term “Company” is defined as “OEP and each of its

affiliates, related entities, subsidiaries, officers, directors, and employees.” A “Tier 1 Participant”

is defined as “a person who is employed by Company, has a Covered Claim and has elected to

receive Tier 1 benefits under this Plan” and expressly included “a Tier 1 Participant’s spouse,

children, parents, estate, successors and assigns.”

The SPD provides that the “Company and Tier 1 Participant intend and expressly agree

that any Covered Claim of Company’s officers, directors, agents, predecessors, successors, and

affiliated companies that arises from, relates to, or is derivative of any Covered Claim of Company,

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MVT Services LLC and Juan Garcia v. Erika Robles Individually, as Representative of the Estate of Orlando Robles, and as Next Friend of K.R., Maria Castillo, Elainna Robles, Athena Schmidt, Melina Robles, Byanca Santos and Paulina Merino on Behalf of Minor Child O.R.R., Counsel Stack Legal Research, https://law.counselstack.com/opinion/mvt-services-llc-and-juan-garcia-v-erika-robles-individually-as-texapp-2024.