United States District Court, N.D. Alabama, Southern Division
JAMES H. HANCOCK, Senior District Judge.
The court has before it the June 17, 2015 Motion (Doc. #3) to Dismiss Without Prejudice, Or, In the Alternative Motion to Stay Action and To Compel Arbitration filed by Defendant Locklear Automotive Group, Inc. Pursuant to the court's June 18, 2015 order (Doc. # 4), Plaintiff filed a Response (Doc. #5) in Opposition on July 2, 2015, and Defendant filed a Reply (Doc. #6) on July 8, 2015. The Motion (Doc. #3) is now under submission, without oral argument, and due to be granted for the following reasons.
A. Procedural History
Plaintiff filed the instant Complaint (Doc. #1) on March 19, 2015, alleging violations of 42 U.S.C. § 1981 and Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. §§ 2000e et seq. Specifically, Vanhorn alleges that his employment with Locklear Automotive was discriminated against and ultimately terminated because of his race, African American. ( See generally Compl.) On June 17, 2015, Defendant filed a Motion (Doc. #3) to Dismiss Without Prejudice, Or, In the Alternative Motion to Stay Action and To Compel Arbitration. The Motion, as supported by the accompanying Memorandum of Law, asserts that Plaintiff signed an Arbitration Agreement whereby he agreed that any dispute relating to his employment would be resolved through arbitration. ( See Exh. A to Doc. #3.)
B. Arbitration Agreement
At the inception of his employment with Locklear Automotive, on September 16, 2013, Vanhorn and Defendant mutually executed a written Arbitration Agreement (the "Agreement"). (Exh. A to Doc. #3.) The Agreement provides:
[T]he Employer and Employee mutually agree that all disputes not barred by applicable statutes of limitations, resulting from or arising out of said employment (including but not limited to... the benefits and conditions of employment...; the relationship between the Employer and the Employee and other Employees of the Employer; the working conditions while employed; the terms, manner and conditions of termination (voluntary or involuntary); the Employer's compliance with any state and/or federal employment and civil rights rules, regulations and laws...) shall be submitted to BINDING ARBITRATION, pursuant to the provisions of 9 U.S.C. Section 1, et seq. and according to the Commercial Rules of the American Arbitration Association then exiting in the County where the Employer maintains its principal place of business....
(Exh. A. to Doc. #3) (emphasis in original.)
Defendant's Motion (Doc. #3) to Compel Arbitration asserts the following grounds for ordering the case to proceed under the terms of the Agreement: (1) that the Federal Arbitration Act ("FAA") governs the case; (2) that the Agreement is valid and binding; and (3) that Plaintiff's claims are within the scope of the Agreement. (Doc. #3 at 2-6). Plaintiff opposes the motion to compel arbitration and argues that the Agreement is unenforceable because it is unconscionable. ( See Doc. #5 at 2-3). The court agrees with Defendant for the following reasons.
A. The Federal Arbitration Act Governs the Case
There is no dispute that the arbitration agreement in this case is subject to the Federal Arbitration Act, 9 U.S.C. § 1 et seq. ("FAA"). ( See generally Doc. #5 at 4). The FAA carries with it certain standards applicable to this court's review of the pending motion.
"In enacting the FAA, Congress demonstrated a liberal federal policy favoring arbitration agreements.'" MS Dealer Serv. Corp. v. Franklin, 177 F.3d 942, 947 (11th Cir. 1999) (citation omitted). As such, "questions of arbitrability must be addressed with a healthy regard for the federal policy favoring arbitration." Franklin, 177 F.3d at 947. "By its terms, the Act leaves no place for the exercise of discretion by a district court, but instead mandates that district courts shall direct the parties to 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). Arbitration "should not be denied unless it may be said with positive assurance that the arbitration clause is not susceptible of an interpretation that covers the asserted dispute." AT&T Techs., Inc. v. Communications Workers of America, 475 U.S. 643, 650 (1986). Pursuant to the FAA, a claim is arbitrable if the following three criteria are satisfied: (1) there is a valid agreement to arbitrate; (2) the claim falls within the scope of the agreement to arbitrate; and (3) the claim, if ...