Martinez v. Sonesta International Hotels Corporation

Background

Martinez asserted eight causes of action arising from his employment relationship with a Sonesta hotel located in San Bruno, California. Sonesta moved to compel arbitration under the Federal Arbitration Act, which generally requires courts to enforce a written and enforceable arbitration agreement covering the dispute.

The arbitration agreement stated that disputes arising from an employee’s employment or termination that could be brought in court must be arbitrated. Martinez contended that he never digitally or otherwise signed the agreement.

Evidence About the Agreement

Sonesta submitted evidence describing its usual hiring and onboarding process. Under that process, an applicant registers on Workday, creates a username and password, completes an online application, and, if hired, uses the account to review and digitally sign onboarding documents, including an arbitration agreement.

Sonesta’s records showed that a Workday account was created in Martinez’s name on August 11, 2021, and that someone using the account digitally signed several documents, including the arbitration agreement, on August 19, 2021. Sonesta argued that Martinez must have created and used the account because he was hired by Sonesta.

Martinez offered undisputed evidence that he began working at the hotel around 2000 through another cleaning company contracted by Sonesta; that he never submitted a job application to Sonesta online or in person; and that, in August 2021, a housekeeping manager gave him a one-page document and explained in Spanish that it concerned his transfer from the cleaning company to Sonesta. Martinez stated that he did not create a Workday username, password, or profile and did not receive onboarding documents through Workday to sign.

Martinez also stated that, in or around 2023, an assistant used a sheet containing employee login credentials, including a password, to sign him into a Sonesta computer so he could complete employee surveys. Sonesta’s records similarly showed that someone used Martinez’s Workday account on five dates from computers associated with the San Bruno hotel, including manager-controlled computers.

Court’s Analysis

Under California law, an electronic signature can have the same legal effect as a handwritten signature. But when a person challenges the validity of an electronic signature, the party relying on it must prove by a preponderance of the evidence—meaning that the claim is more likely true than not—that the signature is authentic.

The court found that Sonesta had not shown that it followed its standard hiring process when it hired Martinez. The court also found insufficient evidence that Martinez participated in the usual Workday onboarding process or that he was the person who accessed the account and agreed to arbitration. Sonesta essentially relied on the assumption that Martinez followed the process typically used by employees, but the evidence that others knew and used credentials for the account supported a different possibility.

Ruling

Judge Maxine Chesney found that Sonesta failed to prove by a preponderance of the evidence that Martinez assented to the arbitration agreement. The court therefore denied Sonesta’s motion to compel arbitration. The court also set a case management conference for December 12, 2025, and required the parties to file a joint case management statement by December 5, 2025.