Jones, Esq. v. Landry's, Inc.
- Gregory Woods
- 1:23-cv-09920
- U.S. District Court · Southern District of New York
- 16
In Jones v. Landry’s, Judge Woods granted arbitration, stayed the case, and left enforceability disputes to the arbitrator.
Joy Vida Jones and the defendants in her employment dispute; the court sent all of Jones’s claims to arbitration and stayed the federal case.
What happened
In Joy Vida Jones, Esq. v. Landry’s, Inc., Jones sued her former employers over race discrimination, retaliation, breach of contract, and related claims. The defendants asked the court to dismiss the claims or send them to arbitration.
Judge Woods ruled that the arbitration question had to be addressed before deciding whether the claims were adequately pleaded. The employment agreement covered all of Jones’s claims, and it gave the arbitrator authority to decide whether the arbitration agreement was enforceable. Jones argued that the arbitration terms were unfair and that the defendants had given up their right to arbitrate, but the court rejected those arguments.
Judge Woods declined to adopt the magistrate judge’s report and recommendation, granted the defendants’ motion to compel arbitration, and stayed the case pending arbitration. The arbitrator, rather than the court, must address disputes about the arbitration terms’ fairness and enforceability.
The detailed version
- Jones, Esq. v. Landry's, Inc. · No. 1:23-cv-09920
- Gregory Woods
- May 29, 2025
Background
Joy Vida Jones sued her former employers for race discrimination, retaliation, breach of contract, and breach of the implied covenant of good faith and fair dealing. The defendants moved to dismiss the amended complaint or, alternatively, to compel arbitration under the Federal Arbitration Act. Magistrate Judge Jennifer Willis issued a report and recommendation advising that some claims be dismissed and the remaining claims be sent to arbitration. The report also recommended severing the arbitration agreement’s fee-shifting provision after finding it unconscionable, meaning unfairly one-sided or unreasonably burdensome.
The parties objected to the report and recommendation. Before this court, Jones argued that the arbitration agreement was unconscionable because of its fee-shifting and fee-splitting provisions and that the defendants had waived their right to arbitrate by filing a motion to dismiss in the alternative.
Court’s Analysis
The court held that it should decide arbitrability—the question whether the dispute must be handled in arbitration—before reaching the defendants’ motion to dismiss. The parties did not dispute that Jones’s claims fell within the arbitration clause. The clause incorporated arbitration rules giving the arbitrator authority to decide questions about the existence, scope, validity, and arbitrability of the agreement.
The court found that Jones had not specifically challenged that delegation of authority. She challenged arbitration generally, including the possible financial burden, rather than explaining why the delegation provision itself was invalid. The court therefore enforced the delegation provision and left the unconscionability questions for the arbitrator. The court also stated that, even if it could decide enforceability, the evidence presented was likely insufficient to establish that the fee-related or forum-selection provisions were unconscionable as applied to Jones.
The court separately held that the defendants had not waived their right to arbitrate. The defendants requested permission to move to compel arbitration by the date their response to the original complaint was due, before Jones filed her amended complaint. The court also noted that the parties had not exchanged discovery and that the alternative motion to dismiss did not amount to extensive litigation.
Disposition
Judge Gregory H. Woods declined to adopt the report and recommendation. The court granted the defendants’ motion to compel arbitration of all of Jones’s claims and stayed the action pending arbitration. The court did not decide the merits of the discrimination, retaliation, contract, or implied-covenant claims. It directed that any dispute about Jones’s ability to attend or pay for arbitration be addressed to the arbitrator, who was empowered to decide issues of arbitrability.
Read the full 16-page opinion on CourtListener, the free public archive maintained by the Free Law Project.