OMNITECH INSTITUTE, INC. v. JASMINE NORWOOD

CourtCourt of Appeals of Georgia
DecidedJune 30, 2021
DocketA21A0294
StatusPublished

This text of OMNITECH INSTITUTE, INC. v. JASMINE NORWOOD (OMNITECH INSTITUTE, INC. v. JASMINE NORWOOD) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
OMNITECH INSTITUTE, INC. v. JASMINE NORWOOD, (Ga. Ct. App. 2021).

Opinion

FIFTH DIVISION MCFADDEN, C. J., RICKMAN, P. J., and SENIOR APPELLATE JUDGE PHIPPS

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

DEADLINES ARE NO LONGER TOLLED IN THIS COURT. ALL FILINGS MUST BE SUBMITTED WITHIN THE TIMES SET BY OUR COURT RULES.

June 28, 2021

In the Court of Appeals of Georgia A21A0294. OMNITECH INSTITUTE, INC. et al v. NORWOOD.

RICKMAN, Presiding Judge.

Omnitech Institute, Inc. and its president, Charleton Lester, (collectively

“Omnitech”) seek interlocutory review of the trial court’s order denying their motion

to compel the arbitration of Jasmine Norwood’s employment discrimination claims.

Omnitech contends that the trial court erred by accepting Norwood’s argument that

enforcement of the arbitration provision would prohibit her from effectively

vindicating her claims because she could not afford the arbitration costs. Because the

issue of arbitration costs is not ripe at this stage of the proceedings, we reverse.

On appeal from a denial of a motion to compel arbitration, we “review[ ] the

record de novo to determine whether the trial court’s denial of the motion to compel

arbitration is correct as a matter of law. However, we defer to the trial court’s findings of fact upon which its denial was based unless those findings are clearly erroneous.”

(Citations and punctuation omitted.) Schinazi v. Eden, 351 Ga. App. 151, 156 (830

SE2d 531) (2019).

So viewed, Omnitech hired Norwood in April 2019 to work as a substitute

teacher. Her employment contract contained an arbitration clause stating that any

claim arising out of her employment would be settled by binding arbitration before

a panel of three arbitrators in accordance with the commercial arbitration rules of the

American Arbitration Association (“AAA”).

Approximately five months after she had been hired, Norwood sued Omnitech.

In her complaint, Norwood alleged that Lester had made multiple unwanted sexual

advances toward her, including grabbing and rubbing against her, and that when she

complained to her supervisor, she was told that the only way to avoid interacting with

Lester was to quit, which she ultimately did. Norwood’s complaint asserted state law

tort claims and federal Title VII sexual harassment and retaliation claims. In response,

Omnitech filed a motion to compel arbitration and dismiss the complaint. Norwood

opposed the motion, acknowledging that she had agreed to the arbitration clause and

that it covered her claims, but asserting that it was nonetheless unenforceable.

2 Specifically, Norwood argued that she could not effectively vindicate her rights

through arbitration because she could not afford the arbitration fees.

The trial court denied Omnitech’s motion to compel arbitration, finding that

“enforcing the [arbitration] agreement will preclude [Norwood’s] effective

vindication of her federal statutory rights.”

Omnitech contends that the trial court erred by accepting Norwood’s argument

that enforcement of the arbitration provision would prohibit her from effectively

vindicating her claims because she could not afford the arbitration costs.

The Federal Arbitration Act (“FAA”) provides that arbitration agreements

“shall be valid, irrevocable, and enforceable, save upon such grounds as exist at law

or in equity for the revocation of any contract.” 9 U. S. C. § 2. This preference for

enforcing arbitration agreements “requires a liberal reading of [such] agreements,”

and any doubts concerning the arbitrability of an issue should be resolved in favor of

arbitration. Krut v. Whitecap Housing Group, 268 Ga. App. 436, 441 (2) (a) (602

SE2d 201) (2004) (citing Moses H. Cone Mem. Hosp. v. Mercury Constr. Corp., 460

U. S. 1, 23 (103 SCt 927, 74 LE2d 765) (1983)). Indeed, even federal statutory

claims, such as the employment discrimination claims Norwood asserts here, may be

resolved through arbitration – “so long as the prospective litigant effectively may

3 vindicate his or her statutory cause of action in the arbitral forum[.]” (Citation and

punctuation omitteed.) Gilmer v. Interstate/Johnson Lane Corp., 500 U. S. 20, 28

(III) (A) (111 SCt 1647, 114 LE2d 26) (1991).

In Green Tree Financial Corp.-Ala. v. Randolph, 531 U. S. 79 (121 SCt 513,

148 LE2d 373) (2000), the Supreme Court recognized that “[i]t may well be that the

existence of large arbitration costs could preclude a litigant . . . from effectively

vindicating her federal statutory rights in the arbitral forum.” Id. at 90 (III). Because,

the record, however, had no information about such costs or who would bear them,

the Supreme Court held that “[t]he ‘risk’ that [the plaintiff] will be saddled with

prohibitive costs is too speculative to justify the invalidation of an arbitration

agreement.” Id. at 91 (III).

The circumstances under which the effective vindication defense would

invalidate an arbitration agreement is an issue of first impression in Georgia. The

Eleventh Circuit has addressed the defense several times in the wake of Green Tree,

but so far has rejected it as too speculative in every case. In Musnick v. King Motor

Co. of Ft. Lauderdale, 325 F.3d 1255 (11th Cir. 2003), the court held that “[u]nder

Green Tree, [the plaintiff] has an obligation to offer evidence of the amount of fees

he is likely to incur, as well as of his inability to pay those fees.” Id. at 1260 (II).

4 Noting that other circuits have taken a case-by-case approach in evaluating the

sufficiency of a plaintiff’s proof, the Musnick court rejected as “wholly inadequate”

the plaintiff’s affidavit stating that he was “fearful of a potential attorney’s fee award

against [him that he] will be unable to pay.” Id. (punctuation omitted). Thus, Musnick

established that a plaintiff resisting arbitration cannot traffic in generalities, but must

instead present specific, dollar-amount evidence of arbitration costs.

Even specific dollar amounts, however, are insufficient unless the plaintiff can

show that she will actually be required to pay them. Further, the plaintiff must show

that she is required to pay arbitration costs at the outset, not just that they may be

assessed later. In Anders v. Hometown Mtg. Svcs., 346 F.3d 1024 (11th Cir. 2003),

the plaintiff, who had borrowed money from the defendant to buy a home, sued the

defendant for violations of federal real estate and lending law. The loan agreement

contained an arbitration clause much like the one here, requiring arbitration of

disputes in accordance with AAA’s commercial dispute rules. Id. at 1026-1027 (I),

1028 (II). The plaintiff argued that he “simply [could] not afford to pay the $3,500.00

to $6,000.00 that [he had] determined w[ould] be required to arbitrate [his] claims.”

Id. at 1028 (II).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Gilmer v. Interstate/Johnson Lane Corp.
500 U.S. 20 (Supreme Court, 1991)
Green Tree Financial Corp.-Alabama v. Randolph
531 U.S. 79 (Supreme Court, 2000)
SOUTHSTAR ENERGY SERVICES, LLC v. Ellison
691 S.E.2d 203 (Supreme Court of Georgia, 2010)
Krut v. Whitecap Housing Group, LLC
602 S.E.2d 201 (Court of Appeals of Georgia, 2004)
Pope v. City of Atlanta
240 S.E.2d 177 (Supreme Court of Georgia, 1977)
Heard v. City of Villa Rica
701 S.E.2d 915 (Court of Appeals of Georgia, 2010)
Reed v. State
727 S.E.2d 112 (Supreme Court of Georgia, 2012)
Willman Suazo v. NCL (Bahamas), Ltd.
822 F.3d 543 (Eleventh Circuit, 2016)
SCHINAZI Et Al. v. EDEN.
830 S.E.2d 531 (Court of Appeals of Georgia, 2019)
EDWARDS v. MOORE Et Al.
830 S.E.2d 494 (Court of Appeals of Georgia, 2019)
Escobar v. Celebration Cruise Operator, Inc.
805 F.3d 1279 (Eleventh Circuit, 2015)
Stubbs v. Hall
840 S.E.2d 407 (Supreme Court of Georgia, 2020)
Hurston v. State
854 S.E.2d 745 (Supreme Court of Georgia, 2021)

Cite This Page — Counsel Stack

Bluebook (online)
OMNITECH INSTITUTE, INC. v. JASMINE NORWOOD, Counsel Stack Legal Research, https://law.counselstack.com/opinion/omnitech-institute-inc-v-jasmine-norwood-gactapp-2021.