Plaintiff Christopher Shinneman sued defendants Cerner Corporation and Oracle Corporation in the United States District Court for the Western District of Missouri raising claims of employment discrimination under the Missouri Human Rights Act (MHRA), Family and Medical Leave Act (FMLA), and Americans with Disabilities Act (ADA). Defendants moved to sever Plaintiff’s claims against Cerner from his claims against Oracle, Cerner moved to compel arbitration, and Oracle moved to dismiss Plaintiff’s claims under Rule 12(b)(6).
Factual Overview
Plaintiff began working for Cerner on April 30, 2018. Oracle later acquired Cerner. Plaintiff alleges that beginning in May or June 2022, he experienced adverse employment actions by both defendants, which continued throughout his employment and after his termination on August 12, 2022. Before Plaintiff’s first day of employment, he and Cerner entered into a mutual arbitration agreement that covered claims relating to his employment, including discrimination, harassment, retaliation, disability, and termination.
Legal Analysis
Motion to Compel Arbitration and Motion to Sever: The Court found that the arbitration agreement between Plaintiff and Cerner was valid and enforceable, and that Plaintiff’s employment discrimination claims fell within the scope of the agreement. The Court rejected Plaintiff’s argument that Cerner waived its right to arbitration by moving to sever the claims, finding that Cerner’s motions to sever and compel arbitration were consistent with its right to pursue arbitration. The Court granted Cerner’s motion to compel arbitration and Defendants’ motion to sever, staying the proceedings on Plaintiff’s claims against Cerner pending arbitration.
Motion to Dismiss: Oracle argued that Plaintiff failed to allege facts establishing an employer-employee relationship between Plaintiff and Oracle, and therefore the Court should dismiss the claims against it. The Court found that at this stage of the litigation, Plaintiff plausibly pled that Oracle acquired Cerner and was his employer for purposes of the MHRA, FMLA, and ADA. The Court denied Oracle’s motion to dismiss, concluding that Plaintiff was entitled to conduct discovery to ascertain the details relevant to his employment relationship with Oracle.
Stay of Claims Against Oracle: The Court sua sponte considered whether to stay Plaintiff’s claims against Oracle pending the outcome of arbitration between Plaintiff and Cerner. Weighing the risk of inconsistent rulings, the extent to which the parties will be bound by the arbitrator’s decision, and potential prejudice from delays, the Court found that a stay of the claims against Oracle was appropriate.
The Court granted Defendants’ motion to sever, granted Cerner’s motion to compel arbitration, denied Oracle’s motion to dismiss, and stayed the entire case pending arbitration.
Schrag on Law 