Victoria Gallegos v. Wal-Mart Stores Texas, LLC

District Court, W.D. Texas·Decided January 28, 2026·No. 5:25-cv-00641·Unknown

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION

VICTORIA GALLEGOS, § Plaintiff § § v. § Case No. SA-25-CA-00641-XR § WAL-MART STORES TEXAS, LLC, § Defendant §

ORDER COMPELLING ARBITRATION AND STAYING CASE On this date, the Court considered Defendant Wal-Mart Stores Texas, LLC’s Motion to Compel Arbitration and Stay (ECF No. 16) and the associated briefing (ECF Nos. 17–18). After careful consideration, the Motion is GRANTED, and the case is STAYED pending arbitration. BACKGROUND Plaintiff Victoria Gallegos alleges that in August 2023, she was shopping at a Wal-Mart store when a steel fixture fell on and injured her. ECF No. 1-3 at 6. At the time of the incident, Wal-Mart employed Gallegos at the store where she was injured. ECF No. 16-6 at ¶ 7; ECF No. 1-3 at 6. The Petition is silent regarding whether Gallegos was acting in the course and scope of her employment at the time of the incident, see ECF No1-3, but she says in her Response that she was not, ECF No. 17. Wal-Mart did not deny that assertion in its Reply. See ECF No. 18. Gallegos sued Wal-Mart in state court, bringing claims for negligence, premises liability, and respondeat superior. ECF No. 1-3 at 6–8. Wal-Mart removed to this court. ECF No. 1.1

1 In her Response, Gallegos requests a remand to state court, arguing that Wal-Mart’s Notice of Removal was untimely. ECF No. 17. But a motion to remand “on the basis of any defect other than lack of subject matter jurisdiction must be made within 30 days after the filing of the notice of removal.” 28 U.S.C. § 1447(c). “Otherwise, [the] plaintiff waives any objection to the . . . defect, and the action proceeds in federal court, even [if] removal was procedurally improper.” Hinkley v. Envoy Air, Inc., 968 F.3d 544, 549 (5th Cir. 2020). Wal-Mart filed its notice of removal in June 2025. ECF No. 1. Gallegos did not request a remand until December 2025, ECF No. 17, long after her 30-day deadline had passed. Gallegos has thus waived her objection that the Notice of Removal was untimely. 1 Wal-Mart filed this Motion arguing that, as a Wal-Mart employee, Gallegos had agreed to a policy requiring arbitration of this dispute. ECF No. 16. The arbitration agreement was in an appendix to Wal-Mart’s occupational injury plan. See ECF No. 16-4 at 49. It requires arbitration of:

(1) any legal or equitable claim or dispute relating to enforcement or interpretation of the arbitration provision in a Receipt, Safety Pledge and Arbitration Acknowledgment form, an Associate training program, or this Policy; and

(2) any legal or equitable claim by or with respect to an associate for any form of physical or psychological damage, harm or death which relates to an accident, occupational disease, or cumulative trauma (including, but not limited to, claims of negligence or gross negligence or discrimination; claims for intentional acts, assault, battery, negligent hiring/ training/ supervision/ retention, emotional distress, retaliatory discharge, or violation of any other noncriminal federal, state or other governmental common law, statute, regulation or ordinance in connection with a job-related injury, regardless of whether the common law doctrine was recognized or whether the statute, regulation or ordinance was enacted before or after the effective date of this Policy)[; and]

(3) The determination of whether a claim is covered by this Policy.

ECF No. 16-5 at 55–56. Gallegos completed a computer-based learning program in which she acknowledged receipt and understanding of the arbitration agreement. See ECF No. 16-3 at 25; ECF No. 16-7. Wal-Mart argues that (1) Gallegos’s claims must be decided by arbitration and (2) the claims’ arbitrability must be decided by arbitration. DISCUSSION I. General Legal Standard 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. The Act “mandates that district courts shall direct the parties to 2 proceed to arbitration on issues as to which an arbitration agreement has been signed.” Dean Witter Reynolds, Inc. v. Byrd, 470 U.S. 213, 218 (1985) (emphasis in original). Deciding a motion to compel arbitration generally involves two steps: “First, the court asks whether there is a valid agreement to arbitrate and, second, whether the current dispute falls within

the scope of a valid agreement.” Edwards v. Doordash, Inc., 888 F.3d 738, 743 (5th Cir. 2018). “Ordinarily both steps are questions for the court.” Kubala v. Supreme Prod. Servs., Inc., 830 F.3d 199, 201 (5th Cir. 2016). But “parties are free to delegate questions to an arbitrator, including questions regarding the validity and scope of the arbitration provision itself.” Arnold v. Homeaway, Inc., 890 F.3d 546, 551 (5th Cir. 2018). “[I]f the party seeking arbitration points to a purported delegation clause, the court’s analysis is limited. It performs the first step—an analysis of contract formation—as it always does.” Kubala, 830 F.3d at 202. But if it finds a valid arbitration agreement, the only remaining question for the court is “whether the purported delegation clause is in fact a delegation clause—that is, if it evinces an intent to have the arbitrator decide whether a given claim must

be arbitrated.” Id. Courts “should not assume that the parties agreed to arbitrate arbitrability unless there is clear and unmistakable evidence that they did so.” Archer & White Sales, Inc. v. Henry Schein, Inc., 935 F.3d 274, 277 (5th Cir. 2019). When the arbitration agreement delegates the question of arbitrability to an arbitrator, “a court possesses no power to decide” whether the parties’ dispute falls within the scope of the agreement. Henry Schein, Inc. v. Archer & White Sales, Inc., 586 U.S. 63, 68 (2019). II. Whether a Valid Arbitration Agreement Between the Parties Exists In deciding the first issue—whether there is a valid agreement to arbitrate—the question is “whether the parties entered into any arbitration agreement at all.” Kubala, 830 F.3d at 201

3 (emphasis in original). Whether the parties “entered a valid arbitration contract turns on state contract law.” Id. Wal-Mart asserts that Texas law applies here, ECF No. 16 at 6, and Gallegos does not dispute that assertion, see ECF No. 17. Texas law provides that the party attempting to enforce an arbitration agreement must show

that the agreement meets all requisite contract elements. Specialty Select Care Ctr. of S.A., L.L.C. v. Owen, 499 S.W.3d 37, 43 (Tex. App.—San Antonio 2016). Under Texas law, “[t]he elements needed to form a valid and binding contract are (1) an offer; (2) acceptance in strict compliance with the offer’s terms; (3) a meeting of the minds; (4) consent by both parties; (5) execution and delivery; and (6) consideration.” Id.

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