Plaintiff Kaylee Williams sued defendants Tasty King, LLC, Diane Roach, and Scott Voorhees in the United States District Court for the Eastern District of Missouri, raising claims under the Fair Labor Standards Act, Missouri’s Minimum Wage Law, and Missouri state law regarding final paychecks, along with a breach of contract claim. Defendants Tasty King and Roach moved to compel arbitration and dismiss the complaint.
Factual Overview
Williams worked at a Burger King restaurant in Hannibal, Missouri, which was owned and operated by Tasty King. Roach served as Williams’ direct supervisor and general manager, while Voorhees was also identified as an owner of the location. Williams signed an arbitration agreement on June 24, 2024, as part of Tasty’s Employee Handbook. The agreement required that any disputes between Williams and the company that could not be resolved through the company’s problem-solving procedure or mediation must be submitted to binding arbitration.
Legal Analysis
Validity of Arbitration Agreement Under the FAA: The court found that the Federal Arbitration Act (FAA) applied to the contract at issue. The court noted that the FAA reflects a liberal federal policy favoring arbitration and requires courts to place arbitration agreements on equal footing with other contracts.
Challenge to FLSA Claims: The court rejected Williams’ argument that the arbitration agreement violated the FLSA’s provision allowing recovery of attorney’s fees and costs. The court found no language in the agreement that would prevent Williams from seeking such relief in arbitration.
Specificity of Agreement: The court dismissed Williams’ argument that the agreement was invalid because it lacked specific terms about the arbitrator, location, applicable rules, and cost allocation. The court noted that the FAA contemplates situations where such terms are not specified and provides mechanisms to address these gaps.
Waiver Argument: The court rejected Williams’ claim that the defendants waived their right to arbitrate by allegedly invoking Rule 11 proceedings, finding no evidence in the record of such proceedings and noting that defendants asserted their arbitration rights from the start of litigation.
The court granted the motion to compel arbitration, stayed the proceedings as to Tasty King and Roach pending arbitration, and ordered the parties to provide a status report within 90 days.
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