Estillore v. Capgemini America, Inc.

Background

Rowena Estillore, proceeding without a lawyer, filed a complaint against her former employer, Capgemini America, Inc. Capgemini moved to compel arbitration under the Federal Arbitration Act, a federal law that generally requires courts to enforce valid arbitration agreements.

Estillore did not file an opposition by the deadline and did not otherwise communicate with the court. In response to Capgemini’s earlier demand for arbitration, she stated that the offer letter did not account for all “charges” and that she was saying no to arbitration.

Agreement and Analysis

The court found that Estillore had accepted an employment contract containing a binding arbitration clause. The clause covered disputes arising out of, relating to, or concerning the employment agreement and the rights, obligations, or other aspects of the employment relationship, including discrimination or retaliation claims.

The court explained that its role under Section 4 of the Federal Arbitration Act was limited to deciding whether a valid arbitration agreement existed and whether the agreement covered the dispute. The agreement incorporated the Employment Arbitration Rules of the American Arbitration Association. Because of that incorporation, the court determined that disputes about the agreement’s scope had been delegated to the arbitrator rather than being decided by the court at this stage.

Ruling

Judge James Donato granted the motion to compel arbitration and dismissed the case. The opinion does not specify whether the dismissal was with or without prejudice.