Velez v. PrimeFlight Aviation Services Inc

CourtDistrict Court, E.D. Wisconsin
DecidedFebruary 4, 2020
Docket2:19-cv-01056
StatusUnknown

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

Bluebook
Velez v. PrimeFlight Aviation Services Inc, (E.D. Wis. 2020).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN

LIONEL VELEZ and VANESSA GUADALUPE,

Plaintiffs, Case No. 19-CV-1056-JPS-JPS

v.

ORDER PRIMEFLIGHT AVIATION SERVICES INC.,

Defendant.

Plaintiffs, former employees of Defendant, bring this collective and class action pursuant to the Fair Labor Standards Act, 29 U.S.C. § 201 et seq., and Wisconsin state law, Wis. Stat. § 109.01 et seq. and Wis. Admin. Code § DWD 274 et seq., for Defendant’s alleged failure to pay its employees for all of the hours they worked and its improper denial of overtime payments. (Docket #1). Defendant contends that Plaintiffs previously agreed to arbitrate any disputes arising out of their employment, and has accordingly filed a motion to dismiss this case and compel arbitration. (Docket #4). Plaintiffs oppose the motion on multiple grounds, including that they never actually agreed to arbitrate. For the reasons explained below, Defendant’s motion will be denied. Defendant requests dismissal for lack of subject-matter jurisdiction pursuant to Rule 12(b)(1), but the correct procedural vehicle is Rule 12(b)(3), which allows dismissal for improper venue. Auto. Mechanics Local 701 Welfare and Pension Funds v. Vanguard Car Rental USA, Inc., 502 F.3d 740, 746 (7th Cir. 2007); Cont’l Ins. Co. v. M/V ORSULA, 354 F.3d 603, 606–07 (7th Cir. 2003). The Federal Arbitration Act (“FAA”), 9 U.S.C. § 1-16, “governs the enforcement, validity, and interpretation of arbitration clauses in commercial contracts in both state and federal courts.” Jain v. de Mere, 51 F.3d 686, 688 (7th Cir. 1995). The FAA embodies Congressional policy favoring enforcement of arbitration agreements. Am. Express Co. v. Italian Colors Rest., 570 U.S. 228, 232–33 (2013). But this policy does not circumvent the need to prove that an agreement to arbitrate was reached. Bigger v. Facebook, Inc., No. 19-1944, 2020 WL 401804, at *4-5 (7th Cir. Jan. 24, 2020). To be entitled to an order compelling arbitration, the moving party must prove that (1) a valid agreement to arbitrate exists, (2) the dispute falls within the scope of that agreement, and (3) the plaintiff has refused to proceed to arbitration on that agreement. Zurich Am. Ins. Co. v. Watts Indus., Inc., 466 F.3d 577, 580 (7th Cir. 2006). Defendant maintains that all three elements are present here. First, Plaintiffs entered into arbitration agreements when they were hired. Specifically, Defendant claims that Plaintiffs filled out electronic forms as part of the onboarding process, which included an arbitration provision that they were required to electronically sign. Second, Plaintiffs’ claims are clearly covered by the arbitration clause, which expressly applies to claims for unpaid wages and overtime. Third, Plaintiffs have not, of course, agreed to arbitrate. Plaintiffs respond by asserting, inter alia, that they did not meaningfully assent to the arbitration clause. They note that Defendant’s explanation of the onboarding process is only a description of Defendant’s general policy, not Plaintiffs’ actual experience. Plaintiffs aver that their onboarding process was different. It was administered by Defendant’s secretaries, who had complete control of the computer as various forms and documents came onto the screen. The secretaries would occasionally ask Plaintiffs for information to input into the forms that appeared but would move through the screens far more quickly that Plaintiffs could read and consider the information displayed. This was true of the arbitration agreement, which Plaintiffs did not read or sign and which the secretaries did not describe to them. When disputes of fact arise in the context of a motion to compel arbitration, the FAA directs that the Court “shall proceed summarily to the trial thereof.” 9 U.S.C. § 4. Prior to reaching trial, however, the summary judgment standard applies. Tinder v. Pinkerton Security, 305 F.3d 728, 735 (7th Cir. 2002). The party opposing arbitration must raise genuine and material disputes of fact in order to warrant a trial. Id. Plaintiffs maintain that they have met this standard and are entitled to a trial on whether they formed an arbitration agreement. In reply, Defendant does not dispute Plaintiffs’ testimony regarding their personal onboarding experiences. Instead, Defendant suggests various reasons by which they may be bound to the arbitration agreement even if their story is true. First, Plaintiffs passively allowed the secretaries to complete the onboarding process and did not ask them to slow down or to print out any forms that flashed on the screen. Second, even without Plaintiffs’ genuine signatures on the contract, their continued employment constituted acceptance of the arbitration agreement. Third, Defendant’s employee handbook references arbitration, giving Plaintiffs notice of the agreement, and again suggesting that they should be held to have indirectly accepted the agreement. The Court finds that, on the record presented, no summary trial on contract formation is necessary. Plaintiffs have presented undisputed testimony that they did not meaningfully assent to the arbitration agreements. Defendant’s only evidence is of its general onboarding policy. It does not present direct evidence that Plaintiffs’ version of events is false. Defendant has not even attempted to demonstrate that the general onboarding policy was actually applied in Plaintiffs’ cases. A trial is therefore unnecessary. The evidence demonstrates that the parties did not reach an agreement to arbitrate. Defendant’s arguments to the contrary lack merit. First, Defendant’s position on Plaintiffs’ passivity is circular and unpersuasive. How could one expect Plaintiffs to take a more active role in the onboarding process when they had no control over the computer which governed that process? More importantly, Plaintiffs never saw the arbitration agreement and its existence was not noted by the secretaries. How could Plaintiffs have been aware of the need to stop the process and carefully review the agreement? Additionally, Plaintiffs could not have authorized the secretaries to sign an arbitration agreement that they never knew existed. Second, Plaintiffs’ continued employment did not constitute assent to the arbitration agreement. This is more accurately a request for the application of estoppel, which is a method by which Plaintiffs could be held to an arbitration agreement they did not sign. Zurich Am. Ins. Co. v. Watts Indus., Inc., 417 F.3d 682, 687 (7th Cir. 2005). Defendant bases its estoppel argument on an assumption that Plaintiffs were aware of the arbitration agreement’s existence because it flashed onto the computer screen at some point. Plaintiffs categorically deny this. Even taking this erroneous assumption as true, Defendant lacks legal support for the proposition that continued employment reflects acceptance of the arbitration agreement. Defendant’s only citation on the point is to an inapposite district court case, Tickanen v.

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Bluebook (online)
Velez v. PrimeFlight Aviation Services Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/velez-v-primeflight-aviation-services-inc-wied-2020.