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Lopez v. Cintas

Citation: Not availableDocket: 21-20089

Court: Court of Appeals for the Fifth Circuit; August 30, 2022; Federal Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

In this case, an employee of Cintas Corporation, working as a local delivery driver, contested the applicability of an arbitration clause in his employment contract, seeking an exemption under the Federal Arbitration Act (FAA) for workers engaged in foreign or interstate commerce. The employee argued that his role, involving the delivery of goods received from out of state, fell within the protected class of workers exempt from arbitration under FAA § 1. However, the court determined that his duties as a local delivery driver did not qualify him as a 'transportation worker' engaged in interstate commerce, thus making the arbitration requirement enforceable. The employee also challenged the arbitration agreement as unconscionable, citing his intellectual disability and the one-sided nature of the contract. The court vacated the lower court's decision regarding the unconscionability claim, directing it to be dismissed in arbitration since such challenges pertain to the contract's validity, which is for the arbitrator to decide under Texas law. Consequently, the court partially affirmed the lower court's decision and remanded the case for arbitration, emphasizing the enforceability of the arbitration clause and the inapplicability of the transportation-worker exemption.

Legal Issues Addressed

Arbitration Agreement Enforceability

Application: The court determined that the arbitration agreement in Lopez's employment contract must encompass all employment-related claims, and questions of unconscionability are to be resolved by an arbitrator.

Reasoning: Consequently, Lopez's unconscionability challenge must be resolved by arbitration, leading to the conclusion that the district court incorrectly addressed the merits of his claim.

Federal Arbitration Act Exemption for Transportation Workers

Application: The court held that local delivery drivers, such as Lopez, do not qualify for the transportation-worker exemption under FAA § 1 because they do not actively participate in transporting goods across state lines.

Reasoning: The conclusion is that these drivers are not 'engaged' in interstate commerce because they do not actively participate in transporting goods across state lines.

Judicial Determination of FAA Exemption

Application: The court confirmed that the question of exemption from the FAA's coverage is a judicial determination that must be addressed prior to mandating arbitration.

Reasoning: Lopez appealed, and the court's review confirmed that the question of exemption from the FAA's coverage was a judicial determination prior to mandating arbitration.

Unconscionability Claims Under Texas Law

Application: Under Texas law, claims of unconscionability pertain to the validity of a contract and must be determined by an arbitrator, rather than addressing the merits of the issue in court.

Reasoning: Under Texas law, unconscionability challenges relate to the validity of a contract, not its existence.